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vxEPA 


United States 
Environmental Protection 
Agency 


Office of Pollution 
Prevention and Toxics 
(7406) 


EPA 744-R-98-006 
June 1998 



U.S. EPA 


Garment and Textile Care Program: 
An Eye to the Future 


1998 CONFERENCE PROCEEDINGS 









































































EPA 744-R-98-006 
June 1998 


Garment and Textile Care Program: 
An Eye to the Future 

1998 Conference Proceedings 


U.S Environmental Protection Agency 
Office of Pollution Prevention and Toxics 
Economics, Exposure and Technology Division (7406) 
401 M Street, SW 
Washington, DC 20460 



77 ^ 3*2 


DISCLAIMER 

This document has been reviewed by the U.S. Environmental Protection Agency (USEPA) and approved 
for publication. It is based on the experiences and opinions of EPA's Design for the Environment partners 
from industry, public interest groups, and research/educational institutions. 

The information in this document reflects the opinions of the individual conference speakers. Mention of 
trade names, products, or services by those speakers who are not USEPA officials does not convey, and 
should not be interpreted as conveying official USEPA approval, endorsement, or recommendation. 



Further, any information on product usage, performance, cost, and sales provided by those individual 
conference speakers, who are not USEPA officials, was not independently corroborated by USEPA. 


ACKNOWLEDGMENTS 


This publication was produced by the Garment and Textile Care Program staff of the U.S. 
Environmental Protection Agency (EPA). The overall Program Manager is Cindy Stroup. 

We appreciate the efforts of all of the contributing conference speakers. We especially want to 
thank the members of the Conference Planning Committee: David DeRosa, Sylvia Ewing, Bill Fisher, 
Bill Seitz, Anthony Star, Mary Ellen Weber, and Manfred Wentz. 

A special thanks is extended to EPA interns, Ian Penn and Denise Dickenson for their invaluable 
assistance during the conference, as well as the staff of Westat, Inc., and Tascon, Inc. 

This document was prepared under EPA Contract number 68-D7-0025 by Westat, Inc., of 
Rockville, MD, under the direction of Karen Della Torre and Kurt Patnzi. The EPA Work Assignment 
Manager is Cindy Stroup. 

To obtain a copy of this or other EPA/Design for the Environment Program (DfE) publications, contact: 

EPA’s Pollution Prevention Information Clearinghouse (PPIC) 

401 M Street SW (3404) 

Washington, DC 20460 
202-260-1023 
fax: 202-260-4659 
e-mail: ppic@epa.gov 

To learn more about The Garment and Textile Care Program, visit our website at: 

http://www.epa.gov/dfe/garment/garment.html 

Any questions or comments regarding this document should be addressed to: 

Cindy Stroup 

Economics, Exposure and Technology Division (7406) 

U.S. EPA/OPPT 
401 M Street SfV 
Washington, DC 20460 


in 



PREFACE 


The DfE Garment and Textile Care Program (GTCP) was initiated after a 1992 international 
roundtable on drycleaning in which industry leaders and EPA agreed that health and environmental issues 
surrounding the drycleaning industry could be addressed effectively through DfE's voluntary, proactive 
approach. The project partnership was established to encourage the development and incorporation of 
environmentally-preferable cleaning methods which professional cleaners can offer to their customers, 
while maintaining or increasing economic viability. Initial efforts focused on the development and 
evaluation of new cleanmg methods, the development of technical and training materials, and the 
publication of information. In 1996, at the DfE Apparel Care Conference, it was recognized that 
decisions made in related industries affect the cleanability of garments, and ultimately the decisions made 
by dry cleaners. 

Representatives of industries such as garment and textile designers, manufacturers, fiber 
producers, drycleaners, and retailers along with the U.S. Environmental Protection Agency, gathered in 
Washington, D.C. on March 31-April 2, 1998, for "Garment and Textile Program: An Eye to the Future." 
Participants shared a common goal: To explore how decisions made by other industries affect the 
incorporation of environmentally-preferable methods into professional cleaning operations. The 
conference was the first step in the evolvement of the GTCP to incorporate a life cycle approach to 
identify upstream industrial issues that impact garment care. 


IV 


Table of Contents 


Page 

OPENING REMARKS 

Mary Ellen Weber, Ph.D., Director, Economics, Exposure and 
Technology Division, U.S. EPA Office of Pollution 
Prevention and Toxics. 4 

TEXTILE CARE INDUSTRY IN TRANSITION 

Manfred Wentz, Ph.D. American Association of Textile Chemists 

and Colorists. 10 

ASSESSING RESIDENTIAL EXPOSURES TO PERC 

Judith Schreiber, Ph.D., New York State Department of Health. 15 

STANDARDIZATION AND TESTING 

Norma Keyes, American Association of Textile Chemists and Colorists. 20 

THE OPPORTUNITY FOR TRANSITIONS PLANNING IN THE FABRIC ARE 
INDUSTRY 

David DeRosa, Greenpeace. 24 

INDUSTRIAL ECOLOGY PARADIGM 

Joseph J. Breen, Ph.D., Green Chemistry Institute. 29 

A CLEANER'S VISION OF THE FUTURE 

Buster Bell, Bell Laundry and Cleaners. 33 

INTRODUCING CUSTOMERS TO NEW CLEANING PROCESSES 

Ed Boorstein, Prestige Cleaners. 35 

THE 100 PERCENT WETCLEANING OPERATION 

Debra Davis, Cleaner by Nature. 39 

A BUSINESS PERSPECTIVE ON WETCLEANING 

Ken Adamson, Canadian Fabricare Association. 42 

KOREAN CLEANERS' CONCERNS 

Max Oh, Federation of Korean Drycleaners Association of 

Greater Washington. 47 

THE FABRICARE INDUSTRY AND CHANGE 

Vic Vandermolen, Canadian Fabricare Association. 49 


1 















INDIANA'S 5-STAR ENVIRONMENTAL RECOGNITION PROGRAM FOR 
DRYCLEANERS 

Dave Wintz, Indiana Department of Environmental Management. 55 

DRYCLEANING ISSUES FACING THE ARMED FORCES 

Joseph J. Nilsen, U.S. Department of Defense. 60 

FABRIC ARE RESOURCES FOR THE 21ST CENTURY 

Sylvia Ewing-Hoover, Center for Neighborhood Technology. 63 

A COMPARATIVE EVALUATION OF WETCLEANING AND DRYCLEANING 

Robert Gottlieb, Ph.D., Occidental College/UCLA. 66 

TAKING AN INDUSTRIAL ECOLOGY APPROACH TO GARMENT AND 
TEXTILE CARE 

Braden R. Allenby, Ph.D., Vice President for Environment, 

Health and Safety, AT&T. 73 

SETTING UP A NATIONAL DISTRIBUTION SYSTEM FOR A NEW CLEANING 
TECHNOLOGY 

Jack Belluscio, President, Global Technologies. 80 

RESULTS OF PILOT STUDY COMPARING NEW TECHNOLOGY 
PERFORMANCE 

Perry Grady, Ph.D., College of Textiles, North Carolina State University. 84 

Charles L. Riggs, Ph.D., Texas Woman's University. 86 

Gary Mock, Ph.D., North Carolina State University, College of Textiles. 90 

TEXTILE CARE WITH GLYCOL ETHERS 

Stephen P. Bates, Ph.D., Rynex Holdings, Ltd. 93 

C0 2 PROCESS TESTING RESULTS 

Craig M.V. Taylor, Ph.D., Los Alamos National Laboratory. 97 

SURFACTANT RESEARCH FOR C0 2 PROCESSES 

Jim McClain, Ph.D., MiCELL Technologies. 101 

CHANGING THE CARE LABELING RULE TO FIT CHANGING TIMES 

Connie Vecellio, Federal Trade Commission. 105 

FABRICARE INDUSTRY PERSPECTIVE 

Jackie Stephens, International Fabricare Institute. 110 

TEXTILE INDUSTRY PERSPECTIVE 

Kay M. Villa, American Textile Manufacturer Association. 112 

CONSUMER PERSPECTIVE 

Nancy L. Cassill, Ph.D., UNC School of Human Environmental Studies. 116 

\ 


2 


















REPORT FROM APPAREL-RETAIL-CONSUMER DISCUSSION GROUP 


Barbara Warren, Chair. 121 

REPORT FROM OUTREACH AND EDUCATION WORKGROUP 

Sylvia Ewing-Hoover, Chair. 122 

REPORT FROM TEXTILE WORKGROUP 

Kay Villa, Chair. 123 

REPORT FROM SCIENCE AND TECHNOLOGY WORKGROUP 

Manfred Wentz, Chair. 125 

REPORT FROM DRY CLEANERS WORKGROUP 

Bill Seitz, Chair. 126 

APPENDIX - LIST OF CONFERENCE ATTENDEES. 128 


3 












































































Garment and Textile Care: An Eye to the Future 


• • • 


Opening Remarks 

Mary Ellen Weber, Ph.D. 

Director, Economics, Exposure and Technology Division 
U.S. EPA Office of Pollution Prevention and Toxics 

Dr. Mary Ellen Weber is the Director of the Economics, Exposure and Technology 
Division (EETD) in the Office of Pollution Prevention and Toxics (OPPT). EETD is 
responsible for all economic, industrial chemistry, chemical engineering, environmental 
fate and transport, and consumer and occupational exposure analyses for OPPT. In 
addition, she is co-founder of the EPA Design for the Environment Program and the EPA 
Green Chemistry Program, both housed in EETD. 


The Economics, Exposure and Technology Division of EPA's Office of Pollution Prevention and 
Toxics is the home for EPA’s Design for the Environment Program, called DPE. The DfE Garment and 
Textile Care Program is sponsoring this conference in order to look beyond drycleaning and to involve 
upstream industries on relevant environmental issues. But first, here is some background on the overall 
DfE Program itself. 

The Design for the Environment Program is a voluntary program based on partnerships with 
individual industrial sectors, usually sectors predominated by small businesses. The program was created 
in 1991 to promote the conscious incorporation of relevant environmental issues into business decisions, 
thereby increasing opportunities for pollution prevention and reducing risk. The DfE Program works 
through voluntary partnerships comprised of a variety of stakeholders from industry, professional 
associations, state and local governments, other federal agencies, the public, environmental organizations, 
labor unions, and community groups. DfE partnerships develop and share information, and create 
incentives for environmentally preferable behaviors and practices. Through DfE, the Agency works with 
stakeholders to find safer ways to do business. 

EPA realizes businesses use certain chemicals because those chemicals perform a desired service, 
not because they are toxic. If a business can be profitable and maintain their market share while using 
safer chemicals, or by using smaller quantities of toxic chemicals, that is the preferable alternative. The 
“bottom line” of the DfE Program is to work in a team with project partners to identify and implement 
environmentally-preferable alternatives that can be successfully incorporated into the particular industry. 

The DfE Program has three overall goals: 

■ To encourage voluntary reduction of the use of specific hazardous chemicals by 
businesses, governments, and other organizations through actual design or redesign of 
products, processes, and technical and management systems. 

■ To change the way businesses, governments and other organizations view and manage for 
environmental protection by demonstrating the benefits of incorporating environmental 


4 


considerations into the up-front design and redesign of products, processes, and technical 
and management systems. 

■ To develop effective voluntary partnerships with businesses, labor organizations, 

government agencies, and environmental/community groups in order to implement DfE 
projects and other pollution prevention activities. 


EPA has undertaken a wide variety of DfE partnership projects to date. Examples include 
fabncare; auto refinishing; printed wiring board and circuit board manufacturing; flat panel display screen 
manufacturing; and several printing industry sectors. Small businesses such as these typically do not 
possess the capital to conduct their own independent technology and process evaluations. In addition, it is 
difficult for small businesses to absorb the financial risks associated with investing in new technologies 
that are not yet fully proven. Often small businesses are unaware they are using chemicals that pose 
human health and environmental concerns. Accordingly, the DfE Program, through its industrial 
partnerships, develops and disseminates information that businesses find useful for adopting pollution 
prevention measures while maintaining profitability and financial viability. 

Each DfE partnership project is custom-designed for a specific industrial sector, or for a subset 
within the industrial sector; for example, flexographers as a subset of the printing industry. Due to the 
nature of information development and dissemination, and the incorporation of industry-wide pollution 
prevention measures, DfE partnership projects are long-term initiatives. The first step in a DfE project is 
to identify project partners and other interested parties. The second step is to form a core team with the 
mission of identifying project goals, ascertaining the scope of the project, and determining an approach 
and activities necessary to attain the goals. In these first two steps, the team does not attempt to address 
all relevant issues and solve all problems. Rather, the focus is on resolving the problems with the most 
likelihood of having a feasible and successful solution. 

Project workgroups are then created to address in detail the partnership’s activities. Generally 
speaking, these workgroup activities encompass five primary elements: 1) the "Cleaner Technologies 
Substitutes Assessment;” 2) training development and delivery; 3) development of incentives; 4) public 
outreach; and 5) evaluation of the partnership project. 

Central to each DfE partnership project is the development of a technical document called the 
“Cleaner Technologies Substitutes Assessment" or “CTSA.” This document is an important compendium 
and analysis of technical information pertaining to pollution prevention opportunities in each particular 
industrial sector. The various pollution prevention options for that industry are examined in terms of their 
relative merits, risks, and impacts with respect to protection of the environment and human health. To be 
more specific, the CTSA addresses both existing and new technologies and discusses the cost, 
performance, and relative human health and environmental concerns associated with each technology or 
process option. Technology options are examined on a comparative basis only. These comparative or 
relative assessments are intended to inform the owners and operators of small businesses. The purpose is 
to provide small business decision makers with the information needed to take environmental issues into 
consideration, along with traditional parameters of cost and performance, when choosing among different 
technology, product design, and production process options. 

In the production of the CTSA, what the DfE Program specifically brings to the partnership is 
EPA’s unique set of tools for risk analysis and risk management decision-making. EPA possesses a range 
of professional skills and technical expertise in critical areas, and over the years has developed methods to 


5 


compile, assess, and present information on relative chemical risks. For example, EPA can assist in 
designing models to predict chemical transport and fate, perform relative risk assessments, or conduct 
economic and fmancial analyses of the impacts of technology, process, and management options. It is 
critical to point out that in conducting these analyses for a DfE project, EPA relies heavily on the industry 
partners for industry-specific knowledge. 

In addition to the development and dissemination of CTSA documents, DfE partnership projects 
involve activities designed to directly assist small businesses with implementing environmentally-fnendly 
and economically-viable alternatives. For example, the projects involve both demonstration initiatives 
and the design, development, and delivery of training programs. EPA has sponsored such opportunities 
within many industrial sectors. Examples in the garment care area include the development of an 
excellent curriculum on wetcleanmg, the many wetcleaning seminars held for drycleaners and other 
interested parties, and the work of the Small Business Development Centers to offer services to 
drycleaners considering incorporating new cleaning processes into their businesses. 

Through each DfE partnership project, EPA collaborates with the partners in developing 
incentives for change. These incentive programs are voluntary and industry-run. They are non-regulatory 
and are not implemented nor enforced by EPA. An example of an EPA-sponsored, voluntary incentive 
program is the 33/50 Program. Under this program, industry participants voluntarily determine how to 
reduce emissions of particular toxins by 33 percent within a certain time frame, and ultimately by 50 
percent by an established deadline. Under the DfE Program, EPA has discussed with the garment care 
industry the development of various incentive programs such as a certification for meeting a standard of 
environmental-friendliness. Perhaps most importantly, however, EPA works with the industry partners to 
identify incentives that may exist in the form of business cost-savings and enhanced customer 
satisfaction. 

DfE partnership projects involve the development and dissemination of public outreach materials. 
For various business owners and operators who are not trained in the technical subject area, a CTSA 
document may seem technically complex and inaccessible. Therefore, to ensure that the information is 
most useful, the DfE projects typically create a range of related fact sheets, brochures, videos, and case 
studies oriented to the lay person. Further, the Agency attends trade shows, professional conferences, and 
other industry-specific meetings to distribute pertinent materials and discuss pollution prevention 
opportunities within the industry. As appropriate, DfE outreach materials are provided in more than one 
language. For example, most materials developed for the garment care industry are provided in both 
Korean and Spanish. 

EPA is committed to the evaluation of each DfE partnership project. The Agency must know 
whether its efforts have provided benefits to the particular industrial sector, and also the degree to which 
those efforts have resulted in the prevention of pollution within that sector. In order to evaluate success, it 
is necessary to track industry trends and customer awareness and behavior. From both a finance 
standpoint and a pollution prevention standpoint, it is critical that EPA knows whether any new or 
different technology investments, or any other new ways of conducting business, have proven to be 
effective and are acceptable to the particular industry. 

In addition to partnering with a wide range of industrial sectors, the DfE Program has established 
partnership projects with various non-industry sectors of our economy. A primary example is the banking 
and finance industry. Financial considerations have long-served as barriers to the adoption of pollution 
prevention practices. Banks readily finance the purchase of pollution control equipment that is required 


6 


by a technology-based regulation. In contrast, banks are hesitant to provide financing for pollution 
prevention measures that are not mandated by regulatory agencies (that is, voluntary measures). For this 
reason, EPA has been examining approaches for reducing these barriers. It is important that EPA and the 
DfE Program partners work together to educate the banking community, and prove to banking officials 
that businesses can significantly reduce their overall financial liability, and also increase profitability, 
through adopting production technologies, service technologies, and business operations that prevent 
incurring waste disposal costs, environmental cleanup costs, and employee health and safety problems. 
Banking officials should understand that it is in their own best interest to support businesses that are 
pursuing pollution prevention opportunities. 

The professional and academic communities also play an important role in DfE partnership 
projects; in the form of both research and education. Regarding research, EPA developed the Green 
Chemistry Program to provide grants for both pure and applied research in the areas of alternative 
synthetic pathways, chemical catalysts, and other chemical considerations. The results of such research— 
when applied—can result in new technologies or industrial process modifications that lessen or eliminate 
the generation of targeted waste and byproduct streams. Creation of the Green Chemistry Program 
reflects EPA’s recognition that the identification of pollution prevention opportunities often requires 
research at the level of the molecule and microorganism. It also reflects the Agency's understanding that it 
is not always only the chemical used by an industry that causes environmental harm, but also that 
environmental problems often stem from the overall chemical manufacturing process. In this vein, the 
DfE Program is attempting to stimulate exciting, new innovations in pollution prevention and industrial 
ecology. In fact, one such innovation in the garment care industry recently received the Presidential Green 
Chemistry Challenge Award. In all DfE partnership projects, the Agency emphasizes the application of 
sound science to inform industry decisions, to develop new or modified technologies and methods, and to 
make the best use of the nation’s tax dollars. 

Another area of DfE-sponsored research is the Department of Defense Green Submarine Project. 
EPA is collaborating with DoD on the Green Submarine project because the results will have very broad 
above-water applications. Products that people need for life in a submarine are identical to products that 
people need for life in their homes and communities. A submarine functions in a manner similar to a city, 
except that waste and byproduct recycling and reuse, and pollution prevention, are imperative. Within the 
enclosed space of a submarine, the use of safer product alternatives such as glues and adhesives is critical. 
EPA and DoD believe that working together it is possible to develop safer products and process systems 
that will, in the future, have applications for civilian life. 

In the area of education, the DfE Program recently created the educational initiative called the 
Partnership for Environmental Technology Education, or PETE. Nationwide, hundreds of community 
colleges in part serve as the vocational training source for much of our industrial workforce. Through 
PETE, DfE is working with community colleges to design pollution prevention curricula. In addition, the 
DfE Program worked with the General Services Administration to encourage the development of "green” 
cleaning products. The Federal government is a large purchaser of commercial products. As a result, 
government’s product demands and purchasing patterns can often stimulate changes in within private 
sector markets. 

With regard to professional garment care, EPA has long-standing concerns pertaining to the use 
of perchloroethylene, or perc. For this reason, the professional garment care industry was chosen to be the 
first DfE partnership project, termed the Drycleaning Project. For many the initial gathering was at the 
landmark roundtable meeting in 1992. The purpose of that meeting was to explore approaches for 


7 


working together in creating pollution prevention opportunities. The goal was to identify clothes cleaning 
methods that would result in reduced exposure to perc. EPA did not want to ban the use of perc, rather the 
Agency wanted to identify means for reducing the human and environmental exposure resulting from use 
of the chemical. In the years smce, the partnership has focused on sharing information and on developing 
the technical information that has formed the basis of the fabricare CTSA. EPA also has supported the 
development of improved perc garment care technologies, as well as entirely new technologies, such as 
the computerized and machine-based aqueous process termed "wetcleaning.” 

The DfE Drycleaning Project produced many accomplishments of which EPA is very proud. 
Drycleaning business owners, garment care experts, environmentalists, labor and community 
representatives, and EPA gathered for the first time to speak openly about pollution prevention 
opportunities. The Professional Wetcleaning Partnership was a product of these interactions with the 
mutual goal to work for the improvement and promotion of wetcleaning. 

During the Fall of 1996, EPA convened an international conference to discuss progress made in 
the Drycleanmg Project and future directions. Stakeholders agreed that while changes within the 
drycleaning industry were necessary to accomplish pollution prevention goals, they were not sufficient by 
themselves to meet longer term objectives. It was recognized that fibers, textiles, and garment 
construction must be compatible with new garment care technologies, and therefore, it was agreed that it 
is necessary to address changes throughout the entire industrial chain ending in garment care. This chain 
extends from fiber development, to textile development, to garment design and construction, to garment 
retailing, and finally to garment care. In other words, in order to achieve a greater level of environmental 
protection, it is necessary to address the upstream decisions that affect the ultimate cleanability of 
garments in “cleaner” technologies. Ultimately, for the extended garment care industry to be successful in 
attaining pollution prevention goals, garments must be compatible with new garment care technologies. 

These ideas were formalized into an "industrial ecology” approach for garment care, and the DfE 
Drycleanmg Project evolved over the following year into the current DfE Garment and Textile Care 
Program, or the GTCP. The expanded GTCP calls for the broadening of the stakeholder base by 
including partners who are experts in textile design and manufacture, in garment design and construction, 
in retail merchandising, and in any other area that influences the successful care of a finished garment. 

The purpose of this conference is to aid participants in moving beyond the narrow focus of garment care 
processes, and to address problems, issues, and ramifications throughout the entire pipeline. 

The mission of the DfE Garment and Textile Care Program is to reinvent the garment and textile 
care industry for the 21st Century by: reducing exposure to perc; introducing environmentally-benign 
practices throughout the pipelme of commerce; and promoting the design, production, and sale of textiles 
and garments that are amenable to environmentally-preferable garment care technologies and practices. 
The goal is to create an industry that is more cost effective, more energy efficient, and more 
environmentally-ffiendly, while addressing pollution prevention across all industries within the industrial 
pipeline. Further, it is necessary to address international considerations. A significant portion of the raw 
material and product markets for some industry partners is not domestic, but lies overseas. For example, 
many garments sold by U.S. retailers are constructed overseas. Also, many textiles used by U.S. garment 
manufacturers are produced overseas. EPA is hopeful that its pollution prevention accomplishments will 
increase the domestic market share and that those accomplishments can be exported to other countries, as 
appropriate. 


8 


A number of key stakeholders are participating in this conference. The Federal Trade 
Commission, or FTC, will explain their newly proposed garment care labeling rule. Of course, the 
garment care professionals, clothing retailers, and textile and garment designers and manufacturers are 
here as active participants. In addition, consumers, consumer groups, environmental groups, and labor 
organizations have actively collaborated in the earlier stages of the Garment and Textile Care Program, 
and are also represented at this conference. For example, labor unions such as UNITE, environmental 
groups such as Greenpeace, standards organizations such as the American Association of Textile 
Chemists and Colonsts, and educational research institutions have all actively participated in the 
Program. In addition to the FTC, other governmental agencies are participating in this conference, 
including: the Occupational Safety and Health Association; the National Institute of Occupational Safety 
and Health; and the Department of Defense. EPA is delighted to see and welcomes all conference 
participants. 

In preparation for the conference, four key workgroups were established and met in mid-January 
of 1998. The four workgroups are: Drycleaning; Textiles; Science and Technology; and Outreach and 
Education. The workgroup meetings involved approximately 140 participants from a variety of relevant 
industries, and marked the inception of a dialogue for change within the garment care industry. During 
these meetings, the participants discussed their vision of the future, goals and objectives, and potential 
approaches for accomplishing their goals. EPA encourages you to continue that dialogue during this 
conference. Presentations and discussions will focus on broad program objectives, the evaluation of new 
and emerging technologies, educating industries throughout the garment care chain, and how best to 
engage upstream industries in the ongoing dialogue. It is hoped that this conference will further the 
discussion of change, including the development of meaningful incentives for change. 

The first order of business is to agree on a common goal. Due to the limited time available, it is 
necessary to concentrate on those issues that can be resolved or on which progress can be made. 

Everyone will agree that all of the conference participants’ time and resources are limited, and should be 
spent wisely. The intent of the DfE Program is to generate environmental and human health benefits 
through the hard work of its voluntary partnerships. Keep in mind that all participants are equal 
stakeholders, and should to speak into the process of developing alternative approaches, and endorsing, 
changing, or rejecting those approaches that are not viable or constructive. It will be necessary for the 
partnership to periodically evaluate their progress and perhaps make mid-course corrections. In addition, 
the Agency invites, and in fact depends on, all partners and conference participants to provide 
constructive feedback on how EPA can be of the most assistance. 

In closing, EPA has high hopes that the discussions and interactions at this conference will 
facilitate raising the pollution prevention goals even higher for the garment and textile care industries. 
Indeed, the focus of all DfE partnership projects is to work with businesses in order to assist them with 
the voluntary incorporation of environmentally sound technologies and practices. The DfE GTCP intends 
to convene future meetings to continue the stakeholder dialogue. These meetings will be scheduled in 
conjunction with other industry events, to the extent possible, in order to ensure the greatest attendance by 
the program’s partners. DfE will continue to look forward to ideas about how the garment care, textile, 
garment design and manufacture, and retailing industries can contribute to a cleaner environment while 
operating profitable and competitive businesses. 


V 


9 



u.s.epa n 


Design for the Environment Program 
“Partnerships for a Cleaner Future” 

Mary Ellen Weber, Ph.D. 

Director 

Economics, Exposure and Technology Division 

Cindy Stroup 
Program Manager 

EPA DE Garment and Textile Care Program 

Economics, Exposure and Technology Division 
Office of Pollution Prevention and Toxics 
U.S. Environmental Protection Agency 
Washington, DC 







Design for the Environment Program 


“Partnerships fora Cleaner Future” 





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DE Vision 


That business 
decision-makers 
integrate 
environmental 
concerns into cost 
and performance 
criteria evaluations 



DE Mission 

To use the Office of Pollution Prevention and Toxic*' 
risk msnsgsmsnt msthodology to inform business 
decisions, which when coupled with incentives, will 
encourage changes in behavior. 


Information 

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Incentives 


DE Methods 


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DE Project Activities 

Typical DIE Pro'/acl activities: 

• Scoping - Minifying parb—n, project scop* end foot* 

• Convening projoct imam • Mining god* and approach 

• Tachnical • deve l opment of CTSA> Infomuttoq product 

• Implementation -Wiring, Incenf vee, demonatreflon* 

• Outraacti • toad* showe, vsrtety of publication* 

• Evaluation - surety, track industry trends 


Scoping Activities 





Convening Project Team 


Technical Activities 


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Performance 


Implementation Activities 

Incentives 

1 


Implementation: Training 

Topics 

• boSvton Provanlon 

• Mon-*»dtonai Otamathr** 

• B«tno** tor mmxiomlKg iniVluUona/ P*rri*n to *j>*ng* 

Training — ► 

Behavior! 

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Demonstrations 


Formats 

• tdf-Mning nsfertais 

• Croup Miring program* 

• Train Ox Mn*r program* 

• On-lit* Miring rinaoMUsSo** 

• TsdwtaJ support loc *Ikj®hs* 





































































Implementation: Incentives 


Implementation: Demonstrations 

• Cartification programs 


• At actual or simulated user facilities 

• Sign-up programs 

• Voluntary industry standards 


• At vocational training fadlitiaa 

• Raducas ragulatory burden 


• Mobile demonstrations at trade shows, 

• Reduces remediation burden 


conventions, and workshops 

• Economic benefits 

• Environmental benefits 


• Video and slide shows to publicize training 


Outreach Activities 


CTSA 

i 


Fact Sheets —► 

Demand 

Csss Studies 

Tr»da t 

ipp 

vlw.'W/ivX'X 

•«-— Publication* 

Shows 




Evaluation Activities 

• Survey Target Communities 

-Batalina and follow-up to maasura changes 

• Awaranaat 

• Attitudas 

• Knowladga 

• Bahavior 

eoel —¥ 


Evaluation Activities, com 

• Track Relevant Industry Trends 
- Cuctomar awaranaat 
-Established incantiva programs 
-Businesses using altamativa tachnologias 
-Salas of altamativa tachnology equipment 


DE Projects 


bdustrv 


Prohssionat/Actfcmlc 

• Dry Qoniaj 


• Get— Chutttry 

• Pitntod Wtrtag Baardi 


• Agggmlgg 

• Prtaflaf 


• Pngngi 

- Ichm PtiMag 


• taaaraaoa 

- Lithography 


• CwtaliwDwdewwl 

- Rtogrtyhy 


• P«mariMpEavWwM»oaM 

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Tochnoiogy Educate* (PETE) 

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Dry Clearing Project 

History 

• Partnership toriMd In May 1W2 with trad* moditoni, 
advarrt producers, arrvtronfrvafrtd group*, labor anions, 
urivariitias, and raaaarch organizations 

• Goa/; To reduce exposure to dry daaninQ aofvanta 

• Objectives: 

- Ma nt iy and avduata poflutton prevent on option* 

- Empower dry daanara and public with information 

- Provide In ce nt ive* for dry daanara L public to changa 



DfE Garment and Textile 
Care Program 


Dry Clearing Preyed 

Accomplishments 

• Establishment of partnerships 

• Reduction in perc use by drycleaners 

• information disseminated 

• Professional Wet Cleaning in Use 

• Emerging technologies on horizon 







Garmant and Taitfla Cara Program 



Overview 

M 


• Mission 

•Approach 


• Vision 

•Ongoing Activities 

• Goals & 

•Workgroups 


Objectives 

•Workgroups 


• Stakeholders 

•New Publications 



Garmant and Taztla Cart Program 

Mission 





Reinvent a more cost-effective, energy efficient, end 
environmentally friendly garment end textile cere 
Industry In the 21st Century by: 

• Reducing 

• Encounglng eeie ^ tm e m memmmuetemt^pttf 


Promoting Mr. 














































Garment and TexfiU Car* Program 

Vision 



Oamaiit and Textile Car* Program 

Goals and Objectives 



• Voluntary, non-regulstory stakeholder process 

to achieve ewstrinabte devriop ro sat and polufoe 
prevention through todi itt rtal ecology 

* Expanding on the existing voluntary 
partnership to Indede stakeholder* r*pro*anting a add* 
array of Intaraato In to* parmant and textl« car* Industry 


* Reestablish the stakeholder procass 

* Promote risk reduction throughout th* industrial 
cycle from fiber manufacture to garment care 


• Promote market fortes to encourage the moat 
cost-effective, energy efficient and environmentally 
benign technologies 



Garment and Texts# Cars Program 

Goals and Objectives, cml 



Garmont and Texts* Care Program 

Key Stakeholders 



• Emphasize science l strengthen core 
technological baee for this industrial sector 

• Develop technology base to support all involved 
industries 

• Leverage government funds with industry and 
academic resources to catalyze rapid developments 


Protoosioaal doth** deenert 

Garmont and textile designers, manufacturers, and retailers 
Consumers and oonsianer group* 

Labor organization* 

Environments group* 

Professional standard setting organizations 
Education/roe eerch Institution* 

Government agendas (Federal, State, Local) 


Garment and Textile Car* Program t 


Garment and Texts* Care Program f ^31 

Approach 1*1 


AoDroach continued L 

Develop a Long Term Plan for the Drycleaning Industry 


Develop a Short Term Operational Plan 

• Heady hro*d program objective* end epproeeb 


• Heady strategic goals end meotunbk objedhtee 

• Heady end eveluate rtemaltve products, nemmm, Mmhghe 


• Estsbish priorities 

• fdbeateoto* effected fcdUs*fataMt«to*»vMbtoMB.pe*tfc 


• Heady customer requirements 

• Engage upstream industries to dbfegu* tor change 


• Pr&Me research dboctian 

• Dmmtepatier*gfea*ndincen<veamr»>mei 


• PnvHe fremmvorit ter key iasOxHone/ bedstone 

• Measure progress bequeotty 

• Periodc*Jy awetoer* progress m—«o afenems 

MOM* —* 


• Revise objective as needed 





























CaraHt and Textile Cara Program 

Approach, continued 

• Organize Strategy Development Workgroup* |coow»«}: 

-Qashaaa teHSetewrfW Raimi 

- Sconce end Technology Quindmm-dC**-***) 

~ TuVhS pta* Vila ate Parry 6 «*>f 1 

- Ol/tTMChWtd EduMOP (*mAw»«*e«8»adty*ia C. a«« Itcm w l 

-Aeeeorf n»oj 

-fi tM (TBO) 

- Consumtr (To) 



Garment and Textile Car* Program 

Ongoing Activities 



• Srrwwfrao fr q and araaorfrw p artnecyttw awoop todmOy. 
later, ar nrf/ ont n ental and consumer groupa 


* StotetehMPtorytoMArth^mendSuhitong^ 

Lone farm Plan tea workprwm aiee gnoi . conference. ate. 

* Outraacf) actMdas Ma nma and rmdaad auticadont. 
EPAJDtE wab at*, SBA/SSDC and workshop* Trade 
Shorn*. dkactataMnga) 


Garment and T«xtil* Car* Program 

Ongoing Activities, coonnood 

• Information CoflecOo n aetMbas: 

- foe m group* Id Mmm raitoa aapar* aT aaelegy auc* aa: 

• CHOcal laa—a la *nw*aaaa n . wiimm , rWOI teywa 

• tapaatwaa tar-ate Banta w ja-caaopa 

• Conbnidng mm l uabo n ofbtamatfva taehnohglas acwvmg 

• Ufa cyda anafyah oftquMCO, atefhod pcaucoQ 

• Fashion daslgn aarktdum daymlopmant pilot rno 

• Outreach efforts to atakahoban &uo*. aaxianr. cap 



Garment and Textile Car* Program 

Workgroup Activities 

• Kickoff meeting* January 12-14,1998 

- 140 participants from range of tadusfcriee 

• Follow-up meetings during Confarance on April 2,1998 

- Everyone at confereeca brvttad to participate 

- Purpose la to recap January re aaOnpe and pian aart atope 

• Future meetings to coincide with other industry events 

- For example, the NCA1 trade a how Saptomber 1998 

- A technical conference In the Ml 













































Garment and Textile Cara Program 

Recent Publications 



• Wat Ciaanlng curriculum far dry damn 

- firm ImTvctr rm*rm* to mgaram pubtcaaon) 

• Ravisad Wat Chanba booktat 

• RidsadfiMgiTCT gtfWf fof dy ekanars 

• RaakadProkctFactShaat 

• Pollution Prmmnbon manual 

• Konan and Spanish Translations 

• Pdk/ttonPrwantionMormabonCharinghouaa: 
(202)260-1023 


Garment and Taxtfla Cara Program 

For more information 



• Updated CHE GTCP watsJta. 

wwapspovi oppti ntrldtd garmantf parmenthtml 

• Cindy R. Stroup, GTCP Program Hanagar. 

hum as-ao-m 

tec 202-XO-M1I 

•Mil: aam^cteayO^MtaaMW 

• GTCP Mama: ian Pm, X2-260-0223 

Danisa Dickanson, 202-260-0103 














Distribution h Sales 














































































































Textile Care Industry in Transition 

Manfred Wentz, Ph.D. 

American Association of Textile Chemists and Colorists (AATCC) 

P.O. Box 12215, Research Park, NC 27709-2215 

Dr. Wentz is an internationally recognized industry leader who is active in several 
national and international professional organizations. He chairs the research committee 
RA 43 on drycleaning of the American Association of Textile Chemists and Colorists 
(AATCC) and is a member of the technical committee on drycleaning of the National 
Fire Protection Association (NFPA). He participates as stakeholder in EPA's Design for 
the Environment (DfE), Garment and Textile Care Program (GTCP). Dr. Wentz is 
currently the President of the International Drycleaners Congress (IDC). He is the USA 
delegate and expert on drycleaning and industrial laundering to the International Standard 
Organization (ISO). He is actively involved in the development of objective test methods 
for textile care labeling at the national and international level. 


INTRODUCTION: 

During the last decade, many drycleaners have installed pollution control equipment and 
measures that significantly lower the emission of perchloroethylene (PCE) into the environment. Because 
of the environmental and health concerns about PCE, which is used by about 85% of drycleaners to clean 
clothes today, a substantial number of cleaners are open-minded about more environmentally acceptable 
alternatives. 

In my presentation, I will review some of the major developments that brought us here today. I 
will also suggest some actions that we must consider as we embark on implementing changes in the 
textile care industry. Initiatives taken this decade by EPA and the textile care industry will be discussed. 
Proven and emerging textile cleaning technologies will be reviewed. The need for objective performance 
and life cycle assessment for all cleaning technologies will be outlined. Some of my comments on 
alternative technologies will be brief since other speakers will address them in more detail. Finally, I will 
emphasize that the textile care industry must become an integral part of the textile and apparel chain. The 
visuals I used in my talk are attached. They contain additional information which complement this text. 

EPA - INITIATIVES: 

In the spring of 1992, EPA's Office of Pollution Prevention and Toxics (OPPT) invited experts 
from industry, government, academia, consumer and environmental organizations to Falls Church, VA for 
an international roundtable on pollution prevention and control in the drycleaning industry. Objective and 
subjective information and opinions about drycleaning with PCE were presented and opportunities for 
pollution control and prevention measures were discussed. At the same meeting, EPA officials outlined a 
new voluntary Program, Design for Environment (DfE), which could be used to address the 
environmental concerns about the drycleaning industry. Shortly thereafter, EPA's DfE drycleaning 
program was initiated. It laid the foundation for several meetings of stakeholders from the industry, 
environmental groups, academia and government to air their views about the future of the drycleaning 
industry. 


10 


In September 1996, EPA held the first major conference on drycleanmg in Washington, DC. It 
brought together stakeholders and members of the textile, apparel and cleaning industries. The theme of 
the conference was "Apparel Care and the Environment - Alternative Technologies and Labeling." EPA 
and several professional organizations sponsored that event, including the American Apparel 
Manufacturing Association (AAMA), the American Association of Textile Chemists and Colorists 
(AATCC), the American Textile Manufacturing Institute (ATMI) and the American Association for 
Testing and Materials (ASTM). EPA published the proceedings of this conference (EPA74444-R-96-002, 
September 1996). Many conference participants felt that because care labeling laws exist, the introduction 
of alternative textile care methods require close coordination with the apparel and textile industries. This 
was acknowledged by EPA and has resulted in the expansion of the drycleaning program to the Garment 
and Textile and Textile Care Program (GTCP) to include stakeholders from the textile and apparel 
industries. 


INDUSTRY MILESTONES: 

Responding to the renewed focus on drycleanmg by Environment Canada and EPA, the 
Canadian Fabricare Association (CFA) organized the First North American Environmental Summit in 
Hamilton, Ontario in December 1993. It was an open forum on all aspects of textile care. The generic 
definition of textile cleaning was discussed and cleaners learned from recognized experts about the status 
of alternative cleaning technologies. It was also an opportunity for the EPA stakeholders to interact with 
industry leaders from Canada as w'ell as the United States. After a senes of open meetings of government 
officials and industry leaders, the Canadian industry made the commitment to implement a pollution 
control program which would reduce PCE consumption in drycleaning by 65% within a set time. 

The American drycleaning industry organized the conference "VISION 2000" in Oak Brook, IL 
in July 1994. The scope of this national environmental summit was very comprehensive. Speakers from 
industry, government, academia and environmental groups shared their views about today's drycleaning 
industry. The meeting focused on environmental liability issues, comprehensive pollution prevention 
programs for PCE cleaners and pollution prevention options with alternative cleaning technologies. 
National and regional trade associations implemented some of the ideas presented at the conference and 
developed programs for their members about environmentally friendlier drycleaning practices and 
alternative technologies. Trade associations continue to generated objective information for their 
members which allows them to make environmentally sound decisions in their plant operations. 


TEXTILE CARE SPECTRA: 

All cleaning processes must clean effectively and maintain or restore the desirable and functional 
attributes of textiles. The non-polar and polar properties of the soils and textiles dictate the parameters of 
any cleaning process. If professional cleaners have access to non-polar (non-aqueous) as well as polar 
(aqueous) cleaning media, they have the tools to satisfy their customer's needs for clean clothes with little 
risk of garment damage. The concept of the textile care spectra considers technology options, cleaning 
mechanisms, textile property issues, and preferred methods for garments cleaning and the garment 
damage potential. More details about these fundamental issues are discussed in the distributed handout 
(Reprint from American Drycleaner, November 1996). 


11 


PROVEN TEXTILE CARE TECHNOLOGIES: 


PCE and petroleum have a long history as commercially viable non-aqueous media in the 
professional textile cleaning industry. The same holds true for conventional wet cleaning. 

Although PCE cleaners have gotten unparalleled environmental scrutiny for using this solvent, 
the record shows that the demand for PCE has been declining by 67 % since 1985. This significant 
reduction was accomplished by installing effective pollution prevention measures in drycleaning plants. 
Both industry and government agencies can take credit for this accomplishment. The mandatory 
NESHAP drycleaning regulations as well as EPA's voluntary DfE program and the commitment of 
drycleaners to better plant management were the primary drivers for this positive change. 

Conventional petroleum cleaning is also a well-understood textile cleaning technology. Just like 
with PCE, there are concerns about its environmental impact. In addition, the fire hazard associated with 
the handling of petroleum solvents is of concern. In fact, the potential fire hazard of petroleum solvents 
was the reason for the industry's move away from it to the non-flammable PCE some 30 to 40 years ago. 
The emerging new hydrocarbon cleaning technology uses refined solvents and sophisticated control 
technologies that virtually eliminate the fire hazard of hydrocarbon solvents. I have summarized the most 
important changes in the attached slides, and speakers will give additional information today. 

Drycleaners did a lot of conventional wet cleaning with water and detergents before the evolution 
of the charged system in non-polar solvents. The proper use of detergents and water in the non-polar 
solvent remove polar, water-soluble soils and stains very effectively and minimize the need for manual 
wet cleaning. The new professional wet cleaning technology has been studied extensively with support 
from EPA's DfE program. It utilizes controlled and more automated equipment and methods. There will 
be a report given about it, so I need to go no further. I believe that drycleaners have sufficient 
information available for informed decision making whether or not to invest in this cleaning technology. 

I see the care labeling laws as the major barrier for advancing wet cleaning. There are efforts 
under way to lower these bamers, but these efforts must generate reliable test methods and objective 
information for apparel manufacturers. We can not expect their support without assuring them that 
professional cleaners using this new process will not damage their products. When a drycleaner wetcleans 
a garment which is labeled "Dry Clean Only" he/she may be financially liable if the garment is damaged. 


EMERGING TEXTILE CARE TECHNOLOGIES: 

New cleaning technologies using liquid carbon dioxide or glycol ethers have been investigated 
and promised for several years now. I have prepared two handouts that describe the principles of these 
two emerging technologies. Also, we have speakers on the program who will give you progress reports 
about these developments. In general, drycleaners are receptive to alternative cleaning technologies, but 
they have grown somewhat skeptical of the hype and the lack of credible information about them. I 
believe this skepticism can be overcome if or when impartial demonstration projects under commercial 
conditions verify the stated claims. There is a definite need for objective cleaning and textile performance 
evaluation, practical performance demonstration and realistic cost and benefit data. 

Common sense and experience should guide us to be very careful about embracing any 
alternative technology if there are no or few environmental and safety regulations on the books. I 


12 


remember the time when PCE was heralded as safe alternative to petroleum solvents, and I remember the 
time when there were no regulations about the environmental disposal of PCE. Today's broad concerns 
about the environment and the analytical tools available for impact assessment call for responsible 
actions. We can expect that the developers of new technologies, EPA, and other regulatory agencies will 
work together and generate meaningful, binding recommendations or regulations for professional textile 
cleaning. 

The points I made earlier in my discussion about wet cleaning apply here too: we must work with 
the textile and apparel industries and give them the confidence that new professional cleaning 
technologies do not damage their products. Otherwise they will not advise their customers to have their 
products cleaned professionally. 


LIFE CYCLE ASSESSMENT FOR ALL TECHNOLOGIES: 

Today, environmental and resource allocation decision-makers are looking holistically at 
products and processes before they decide which product or process to choose or endorse. This approach 
is often referred to as industrial ecology. Environmental life cycle assessment of a product or process 
from "cradle to grave" may shed new light on the things we intuitively take for granted. For example, it is 
easy to believe that cotton is less energy intensive than polyester because cotton is a "natural product" and 
polyester is a "synthetic product." Yet, research done after the energy crisis in 1974 demonstrated quite 
conclusively that over their respective product life cycles, garments made out of polyester demand less 
energy than those made of cotton. The same may hold true for their environmental impact if one considers 
that pesticides are used during the growing of cotton. 

As new textile care technologies are developed, we must compare them holistically with existing 
technologies. We must look at product and process parameters. We must collect information on toxicity 
and exposure of new solvents, and we must have objective assessments and evaluations of their impact on 
people and on the environment. We must go beyond technical and economic decision points and include 
political and social issues in our selection process. Clearly, this approach requires multidisciplinary 
expertise far beyond the resources available to the drycleaning industry. I hope that EPA uses industrial 
ecology and life cycle methodology in their assessment of emerging technologies. Drycleaners look to 
EPA for answers. 


SUMMARY: 

1. EPA's voluntary Design for the Environment (DfE), Garment and Textile Care Program (GTCP) 
has opened dialogues among its stakeholders and has led to better understanding of each others 
assessment of the drycleaning industry. 

2. The drycleaning industry has implemented pollution control and prevention measurers that have 
significantly reduced its demand for perchloroethylene (PCE). 

3. The concept of textile care spectra provides useful guidelines for the boundary conditions of 
cleaning technologies. 


13 


4. Proven cleaning technologies available to drycleaners today include non-aqueous drycleaning with 
PCE and petroleum (hydrocarbon) solvents and wet cleaning. 

5. Emerging textile care technologies involving liquid carbon dioxide and glycol ethers appear to be 
promising alternatives, but they have not yet been demonstrated as drop-in alternatives for proven 
technologies. 

6. Successful implementation of alternative textile care technologies requires the involvement of the 
textile and apparel chain. 

7. Life cycle assessment and industrial ecology methodology should be used by decision makers to 
compare the viability of proven and emerging textile care technologies. 

8. The drycleaning industry is looking to EPA for objective assessment and approval of proven and 
emerging textile cleaning technologies. 


14 


OVERVIEW 


TEXTILE CARE INDUSTRY 
IN TRANSITION 

Dr. Manfred Wentz 

EPA-GTPC CONFERENCE: 

AN EYE TO THE FUTURE... 

WASHINGTON, DC 
MARCH 31-APRIL 2. 1998 


• INTRODUCTION 

• EPA - INITIATIVES 

• INDUSTRY MILESTONES 

• PROVEN TECHNOLOGIES 

• EMERGING TECHNOLOGIES 

• LIFE-CYCLE ASSESSMENT 

• SUMMARY 


EPA - INITIATIVE 

• INTERNATIONAL ROUNDTABLE: 

POLL UTION PREVENTION A ND 
CONTROL IN THE DRYCLEANING 
INDUSTRY 

Falls Church, VA 
May 27-28,1992 


EPA-INTERNATIONAL 
ROUNDTABLE AGENDA 

• EXPOSURE REDUCTION 

• RESIDUAL REDUCTION 

• FOOD AND RESIDENT EXPOSURE 
REDUCTION 

• GROUND-WATER CONTAMINATION 

• CAPITAL FORMATION 

• REGULATORY ACTIVITIES 

• INFORM A TION DISSEMINA TION 


EPA - INITIATIVE 

• APPAREL CARE AND THE 
ENVIRONMENT: 

u ALTERNATIVE TECHNOLOGIES 
AND CARE LABELING” 

Washington, DC 
September 9-10, 1998 


EPA - APPAREL CARE 
AGENDA 

• EPA - D/E DRYCLEANING PROJECT 

• EPA's RESEARCH PROGRAM ON 
ALTERNA TIVE TEXTILE CARE 
TECHNOLOGIES 

• EUROPEAN TEXTILE CARE RESEARCH 
REPORTS 

• TEXTILE CARE SPECTRA AND CARE 
LABELING 

• FTC CARE LABELING REVISIONS 

• INDUSTR Y VIEWS ON CARE LABELING 










EPA-DfE PROGRAM 
OPPORTUNITIES 


INDUSTRY MILESTONE 

• VOLUNTARY PROGRAM 


• FIRST NORTH AMERICAN 

• STAKEHOLDER INTERACTION 


ENVIRONMENTAL SUMMIT: 

• POLLUTION CONTROL AND 

PREVENTION 


u OPEN FORUM ON TEXTILE CARE " 

• TEXTILE CHAIN INTEGRATION 

• OUTREACH 

• TECHNOLOGY TRANSFER 

• RESEARCH SUPPORT 


Hamilton, Ontario, Canada 

December 3-4, 1993 


SUMMIT AGENDA 


GENERIC DEFINITION OF 


• AL TERNA TIVE TEXTILE CARE 


FABRICARE 

• BREAK INTERACTION FORCES 

TECHNOLOGY 


BETWEEN SOIL AND TEXTILE 

• POLLUTION CONTROL OPTIONS 



• REDEFINITION OF FABRICARE 


• TRANSPORT SOIL AWAY IN ANY 

• INFORMA TION EXCHANGE WITH 


MEDIUM -LIOUID, GAS, SOLID 

- Environment Canada 



- U.S... EPA 


• CONCENTRA TE SOIL FOR PROPER 

- Environmental community 


DISPOSAL 


GENERIC DEFINITION OF 
FABRICARE (cont.) 

• MUST BE ENVIRONMENTALLY 


INDUSTRY MILESTONE 

• VISION 2000: 

ACCEPTABLE 

• MUST BE ECONOMICALL Y FEASIBLE 


U THENATIONAL DRYCLEANING 
ENVIRONMENTAL SUMMIT 

• RESTORE ORIGINAL TEXTILE 



ATTRIBUTES 


Oak Brook, IL 

July 8-10, 1994 










VISION 2000 AGENDA 


VISION 2000 AGENDA cont. 

• INTRODUCTION AND ISSUES: 


• INTRODUCTION AND ISSUES: 

INDUSTRY GROUPS 


EXTERNAL GROUPS 

- Drycleaners 


- Regulatory agency 



- Insurance industry 

- Suppliers 


- Financial industry 



- Real estate industry 

— Solvent producers 


- Environmental community 


VISION 2000 AGENDA (cont.) 


RETROACTIVE LIABILITY 


INITIATIVES 

• RETROACTIVE LIABILITY 


• SMALL BUSINESS FABRIC CARE 

• COMPETENCE AND A UDIT ISSUES 


SUPERFUND COALITION 

• PERFORMANCE CRITERIA 

• ALTERNATIVE CLEANING 


REA UTHORIZA TION PROPOSAL 

TECHNOLOGIES 


- Environmental Response Fund 

• RESPONSIBLE CARE INITIATIVES 


- Enhanced pollution control measures for 
perc plants 


POLLUTION PREVENTION 


POLLUTION PREVENTION 

IN PERC PLANTS 


IN PERC PLANTS cont. 

• RESPONSIBLE HAZARDOUS WASTE 
MANAGEMENT FOR ALL PLANTS 


• INSTALLATION OF SPILL 

CONTAINMENT STRUCTURES 

• ZERO DISCHARGE TO SANITARY 

SEWER 


• APPLICATION OF FLOOR SEALANT 

• DRY-TO-DRYMACHINES WITH 


• CLOSED PERC DELIVERY SYSTEMS 

RE FRIG ERA TED CONDENSERS 




3 








INDUSTRY MILESTONE 

INITIATIVE IN CANADA: 
CFA-FLARE-ENVIRONMENT CANADA 

“RESPONSIBLE FABRICARE" 


Toronto, Canada 



GARMENTS AND HOME 

November 19-20, 1994 

1 

| 

ll * ' - ll N ^\ 


FURNISHINGS" 

i 

\vwi -fjc-gy 




RESPONSIBLE FABRIC ARE 

• TENET 1: 

U T0 PROVIDE THE BEST 
PROFESSIONAL CLEANING AND 
FINISHING OF CUSTOMER S 



RESPONSIBLE FABRICARE 


RESPONSIBLE FABRICARE 


• TENET 2: 


• TENET 3: 


“TO USE ENVIRONMENTALL Y 
RESPONSIBLE PRA CTICES AND 
PROCESSES" 



“TO PROTECT THE HEAL TH AND 
SAFETY OF CLEANING PERSONNEL 
AND GENERALLY ACT AS 
RESPONSIBLE EMPLOYERS" 





RESPONSIBLE FABRICARE 


INDUSTRY MILESTONE 

• TENET 4: 



• CFA-ENVIRONMENT CANADA 

“TO BE A GOOD CITIZEN IN THE 


CONFERENCE: 

COMMUNITY AND THE FABRICARE 
INDUSTRY" 


“THE FUTURE IS HERE" 




Toronto, Ontario 


fy/- - v-r. 


February 27-28, 1998 


■ ^ i 

UmTj 




4 






























CFA-EC CONFERENCE 


CFA - EC CONFERENCE 


AGENDA 


AGENDA 

• ENVIRONMENT CANADA’S 



STRATEGIC OPTION PROGRAM (SOP) 


• STRATEGIC OPTION REPORT (SOR) 

STRATEGIC GOAL: 



DISCUSSION WITH DR YCLEA NERS: 

REDUCE PERC CONSUMPTION 







- Haw to achieve goal 

Year 

CMuapuso 

Perceacate 







1996 

4J kT 

100 


- Implementation procedures 

2000 

1.6 kT 

35 



Reduction 

2.9 kT 

65 




TEXTILE CARE SPECTRA 

• TECHNOLOGY OPTIONS 

• CLEANING MECHANISM 

• TEXTILE PROPERTY ISSUES 

• PREFERRED METHODS FOR 
GARMENTS 

• GARMENT DAMAGE POTENTIAL 


TEXTILE CARE PROCESS 
SPECTRUM 
Technology Options 



Non-Aqueous Cleaning 


• PERC 

• PETROLEUM 

• CARBON DIOXIDE (?) 

• OTHERS (?) 



Aqueous Cleaning 


• MANUAL 

• WETCLEANING 

• INDUSTRIAL 

• HOUSEHOLD (?) 


PROVEN TECHNOLOGIES 

• A 'OH-AQUEOUS CLEANING: 

- Perchloroethylene (Pare) 

- Petroleum Solvents 

• AQUEOUS CLEANING: 

- Professional Wet Cleaning 


PROVEN TECHNOLOGY: 
PERC 

• MOST VERSATILE TEXTILE CLEANING 
MEDIA 

• MOST REG ULA TED DRYCLEANING 
PROCESS (FEDERAL AND STA TE) 

• HEALTH AND ENVIRONMENTAL 
CONCERNS ABOUT PERC 


5 

















PROVEN TECHNOLOGY: 
PERC 

• SCIENTIFIC LITERATURE CONTAINS 
MANY PEER-REVIEWED STUDIES ON 
TOXICITY OF PERC 

• NO CONSENSUS ABOUT TOXICITY OF 
PERC TO HUMANS 

• PUBLIC OPINION ABOUT PERC IS 
MIXED 


PROVEN TECHNOLOGY: 
PERC 

• POLLUTION PREVENTION 
MEASURES ARE IN PLA CE: 

- New machines are efficient 

— Waste management is available 

- Regulatory frame work exists 

- Associations offer environmental education 


PROVEN TECHNOLOGY: 
PERC 

• PERC DEMAND 
BY AMERICAN DRYCLEANING 
INDUSTRY HAS 

SIGNIFICANTL Y DECLINED 

DURING THE PAST DECADE 


PERC DEMAND: 
(QUANTITIES) 



•■3 14 17 1« H 10 II 12 1J 14 13 14 17 


Year 



PROVEN TECHNOLOGY: 
PERC 

• IMPORTANT SURVIVAL ISSUES FOR 
DRYCLEANERS: 

- Retroactive liability 

- Objective assessment remediation technologies 

- Attainable clean-up standards 


6 














PROVEN TECHNOLOGY: 
PETROLEUM SOLVENT 

• CONVENTIONAL TECHNOLOGY 
WELL DOCUMENTED 

• CONCERNS ABOUT 

— Fire and explosion hazard 
— Air pollution (VOQ 

• MOSTDRYCLEANERS SWITCHED TO 
PERCIN THE * SOS AND 60S 


PETROLEUM SOLVENTS: 
FIRE HAZARDS 

• FLASHPOINT 

■ FLAMMABLE (EXPLOSIVE) LIMITS 

- Lower explosive limit (LEL) 

- Upper explosive limit (UEL) 

• AUTO-IGNITION TEMPERATURE 


PETROLEUM SOLVENTS: 
FIRE HAZARD 

FIRE TRIANGLE: 



PETROLEUM SOLVENTS: 
FIRE HAZARDS 

• FUEL: 

- Solvent vapors are fuel 

- Causes fire when vapor concentration is 
within flammable limits 

• CONTROL: 

- Keep concentration outside flammability 
limits 


PETROLEUM SOLVENTS: 
FIRE HAZARDS 

• OXYGEN: 

- Oxygen required to support flames 

- Normal air contains 21% oxygen 

• CONTROL: 

- Keep oxygen below 8% 


PETROLEUM SOLVENTS: 
FIRE HAZARDS 

• SOURCE OF IGNITION: 

— Flame, spark or excessive heat can ignite 
vapor 

• CONTROL: 

- Avoid open flame and static electricity 

- Use approved electrical wiring 










NEW EQUIPMENT 
TECHNOLOGY 

• MODIFIED CLOSED DRYING CYCLE: 

- Vacuum drying 

- Inert nitrogen blanket 

- Controlled air flow 


PROVEN TECHNOLOGY: 
WET CLEANING 

• PROFESSIONALS CONSIDERS WET 
CLEANING AS SUPPLEMENTARY 
CLEANING TECHNOLOGY 

• EPA's WET CLEANING PROGRAM 
PROVIDES USEFUL INFORMA TION 

• OUTREACH PROGRAM MUST 
INCLUDE INDUSTRY PARTNERS 


BARRIERS FOR WET 
CLEANING 

• QUESTIONS ABOUT U NEW WET 
CLEANING TECHNOLOGY' 

• INVESTMENT AND LABOR COSTS 

• WATER SENSITIVE GARMENTS 

• CARE LABELING ISSUES 

• IMPLEMENTATION STRATEGY 


EMERGING 

TECHNOLOGIES 

• LIQUID CARBON DIOXIDE 

• GLYCOL ETHERS 

• OTHERS (?) 


TECHNOLOGY 


LIFE CYCLE ASSESSMENT 

ASSESSMENT NEEDS 


FOR ALL TECHNOLOGIES 

• OBJECTIVE CLEANING 



PERFORMANCE EVALUA TION 


• PRODUCT AND PROCESS 

• TOXICITY AND EXPOSURE 

• PRACTICAL PERFORMANCE 


• ENVIRONMENTAL IMPACT 

DEMONSTRATION 


• POLITICAL AND SOCIAL ISSUES 

• PRACTICAL COST AND BENEFIT 



DATA 










PRODUCT AND PROCESS 

• RESOURCE AVAILABILITY AND 
CONSUMPTION 

• PROCESS AND MATERIAL 
PERFORMANCE 

• COSTS AND ECONOMIC FEASIBILITY 


TOXICITY AND EXPOSURE 

• TOXICITY 

• EXPOSURE 

-Acute 

- Occupational 

- Chronic 

- Environmental 

- Carcinogenic 

- Community 

- Other 

- Other 


ENVIRONMENTAL IMPACT 

• AIR 

• ATMOSPHERE 

• WATER AND SOIL 

• SOLID WASTE 


POLITICAL AND SOCIAL 
ISSUES 

• LEGISLATIVE STATUS 

• REGULATORY STATUS 

• LABOR IMPACT 

• COMMUNITY IMPACT 

• GLOBAL IMPACT 


'G&S&tf. TEXTILE CARE 

3—ggt INDUSTRY: 




SUMMARY 

s 1S32353 


• TEXTILE CARE INDUSTRY CONSISTS 

OF SMALL BUSINESSES 



• PERC IS STILL CLEANING SOLVENT 



OF CHOICE 



• MOST DRYCLEANERS ARE 

PART 

OF TEXTILE CHAIN pTSt; 


ENVIRONMENTALL Y RESPONSIBLE 


9 




















SUMMARY (cont) 

• INDUSTRY INFRA STRUCTURE DOES 
NOT SUPPORT BASIC RESEARCH 

• DR YCLEANERS EXPECT OBJECTIVE 
GUIDELINES ON ESTABLISHED AND 
EMERGING TECHNOLOGIES FROM 
EPA 



Assessing Residential Exposures to Perc 

Judith Schreiber, Ph.D. 

New York State Department of Health 

Judith Schreiber is a senior research scientist in toxicology who has been working for the 
New York State Department of Health for nearly 20 years. She is a recognized expert in 
risk assessment and risk management issues, especially regarding exposure to 
environmental chemicals, transport of chemicals in humans, and evaluation of the health 
impacts of chemical exposures. 


Every time I go to a new city—and I have been to Washington before, but every time I do go to a 
new city, I usually look in the phone book and try to see how many drycleaners there are in the particular 
city that I am in. I got here so early today that I didn't have time to actually check into my hotel room, but 
I would guess that there are at least several hundred drycleaners in the Washington area. And I would 
hazard a guess that at least some of those share building space with residents or other businesses, like 
offices or other small commercial entities. 

I mention this because in New York we have done quite a bit of work looking at the impact of 
small neighborhood drycleaners on residential and business neighbors. That is the topic of my talk today. 
We have recognized over the years that we have been doing this work that exposure from drycleaners to 
the neighbors who live and work nearby is quite significant. We believe this is a public health concern 
that needs to be addressed by both the industry and the government. 

Drycleaning has a fairly simple approach. How many of you are actually drycleaners out here, if 
I might ask? Maybe less than half, a quarter or so perhaps? As you know, drycleanmg has really evolved 
technologically. This is, of course, a very simple representation of what cleaning is about, but transfer 
machines going to dry-to-dry machines have improved our ability to control the emissions from 
drycleaning facilities. 

Sometimes however, high tech turns into low tech. As you can see, this piping around the 
drycleaning machine is held together by socks. This is the old sock method. You may wonder in your 
home washing machine and dryer about those missing socks. Well, apparently it also happens in 
drycleaning plants because here you have what may be a very sophisticated unit but it is held together by 
socks, which is not very reassuring. 

As was mentioned by other speakers, perc is a toxin and, depending on the amount to which you 
are exposed, can certainly be responsible for health effects. It can cause central nervous system 
intoxication; liver damage; and eye, lung, skin and mucus membrane irritation. There are concerns about 
its cancer potential because of studies in experimental animals and a growing body of evidence in the 
occupational sector indicate that drycleaning workers are at a small but significant increased cancer risk. 

Of course, as we have heard before, perc is widely used in the drycleaning industry. Because of 
its volatility, inhalation is by far the major route of exposure both for workers and for residents who live 
nearby. Perc, once it is breathed in, is absorbed into the body via the lungs. It crosses over to the blood 
and once it is in the blood, it circulates through the body and has a particular affinity for fatty tissue. It is 
stored in body fat of the person who absorbs it. The reason actually that I first became interested in this 


15 


question because I was doing a doctoral dissertation looking at breast milk contaminants. We were also 
doing some work in the health department, looking at air levels in apartments near drycleaners and 
finding quite elevated levels. I put two and two together and thought, if there are lactating mothers living 
in these apartments, breathing in elevated levels of perc, what is going on with their breast milk? Would 
we see some contamination in breast milk? 

I did a lot of work looking at mathematical models that predicted the level that would be present 
in milk as a result of the mother's inhalation of concentrations that we had measured in peoples' homes. 
That is how I began thinking about it and looking at it and realizing that it is a public health concern that 
we all should be aware of and try to address. 

PCBs, once they are in your body fat, are very hard to get rid of. Perc, on the other hand, because 
it is volatile, can also be breathed out. You breathe it in and some of it gets absorbed in the blood, but a 
lot of it gets breathed right back out unchanged. 

This is a picture of an infant's bedroom. We first began this interest in looking at drycleaner 
situations back in 1989 in Putnam County, a rural county in Upstate New York. A woman who lived with 
her family in a small apartment above a drycleaner called the county health department and was 
concerned because she was smelling the odor of drycleaning chemicals in her apartment. This was on a 
small main street in Upstate New York, not New York City. County health department officials, who 
didn't really know how to analyze for that chemical, came to the state health department to ask our 
assistance and together we went in to look at the apartment. 

On the slide you can see a small monitoring device in the comer underneath that teddy bear. 
Basically, we took a 12-hour sample after we had set up the equipment in this child's room, and we found 
in that bedroom levels exceeding the OSHA standard, the OSHA PEL, for this chemical. 

In 1989, in the second floor apartment, we found 197,000 micrograms per cubic meter. I know a 
lot of you are industry folks and you are more used to parts per million. Roughly 7,000 micrograms per 
cubic meter is equal to 1 PPM. That is an extremely high level. As you go across, you can see the levels 
drop, but they are still quite high even at 5,500. That is a little less than a part per million. But remember 
now, this is in a residential apartment nght upstairs from the drycleaning facility. 

The levels had dropped because of a number of things. One, the county health department closed 
down the facility for a time while they could make repairs in the machinery and try to get the levels 
reduced upstairs. Over the course of time, the levels remained elevated and eventually the drycleaner 
closed. Outside the window, on the ledge, you see those levels also are extremely high. So, this was our 
wakeup call. We really do consider this a kind of a red flag that happened to us. 

We thought that these numbers are extraordinary. Why should they be so high in an apartment 
upstairs from the facility when the facility itself has an OSHA PEL? If the apartment is exceeding it, 
well, what is going on downstairs? It was really quite extraordinary. 

In the general population, we found about 25 micrograms per cubic meter in your house or mine, 
assuming we don't live near a drycleaner. This agrees well with EPA's data. These levels are found 
because we bring in drycleaned clothing or we have certain consumer products that contain perc. 

Compare that to the levels that I showed you on that other slide, where we are talking about tens and 
hundreds of thousands of micrograms per cubic meter. 


16 


As a result of that finding, we decided to embark on a study. We asked, is this a fluke or is this 
something that happens commonly with drycleaners in residential buildings? We really didn't know. It 
turned out that nobody really had looked at this except for some studies that had gone on in Germany. I 
think Dr. Kurz and colleagues had done some work at that time. 

So, we looked in Albany, where the state health department is located. We found a hundred 
drycleaners total in the tn-cities area, in the capital district. Only six of those were residential apartments 
in the same building as the drycleaners and we looked at each of those six apartments. So, we looked at 
the universe of residentially located drycleaners in the Albany area. What we found confirmed our 
suspicions about what was going on. It was unusual. We still haven't found one apartment with as high 
levels as that very first one. But look at the levels that we do see. 

We looked at a dry-to-dry machine, but it was in poor operating condition, had bad gaskets, was 
run into the ground. The operator was really not conscientious at all and we found levels from 36,000 to 
55,000 with a mean of about 45,000. What is not presented here, but I want to point out, is that we took 
two 12-hour samples. We took a 12-hour sample in the apartment during the time when the drycleaner 
was operating, 7:00 in the mommg until 7:00 at night. Then we took a subsequent air sample, 7:00 at 
night until the following mommg. If you asked me before we did this, I would have told you that I 
expected that the level would go way up in the daytime and way down at night. But it didn't happen. 
What we found was the levels were very high during the daytime and they stayed at about 80 percent of 
that at night. 

That was a big surprise to our staff when we first did this. We really did not expect that finding, 
but we have now confirmed it time and time again in other studies that we have done. These other 
machines in the middle were transfer machines and the last two there were in apartments above 
drycleaners that used good, well-run dry-to-dry machines. The numbers range from 100 to 440. So, there 
really was a vast array of differences, depending on the type of machine that was used in the facility. 

This confirmed to us that we did stumble upon a problem of indoor air contamination of a rather 
large magnitude as a result of drycleaners. Drycleanmg establishments from a regulatory standpoint, had 
been pushed to the side because they were small, mom and pop style operations, using only a hundred or 
200 gallons of solvent a year. What we came to realize was that those hundred gallons are lost to the air, 
as was alluded to by some other speakers, and that air travels through somebody's apartment on the way 
out. That is the problem. 

I have a lot of respect for drycleaners. I think you are hardworking people. You want to do the 
right thing, but you have a tough job and the problem is your neighbor is ten feet away from you. Your 
neighbor is ten feet on top of you and ten feet to the side of you and that makes it very difficult. Even a 
conscientious drycleaner with good equipment has a really tough job to try to control those emissions. I 
have a lot of empathy for the drycleaners. 

Here, in control apartments, the mean is about 28, which is very similar to what we find 
nationwide. This one, I just want to point out, is the first high rise building that we had looked at. I think 
the common wisdom is that perc is denser than air and it will tend to stay low in the facility workplace. 
We found time and time again that the air currents, convection currents in a building, quickly overwhelm 
the very little density difference between perc and air and, in fact, the perc does travel and migrate 
throughout the building. 


17 


On the second floor, where this complaint call first came in, we found 62,000 micrograms per 
cubic meter in the daytime, 48,000 at night. That was very typical of what we find. Then as you go up, 
we took the fourth floor, the seventh floor, and we looked at the 12th floor, the top of the building. At the 
time we looked at it as an internal control. We did not expect to find anything on the 12th floor, not at all. 

What we found, as you can see, is that the levels on the 12th floor were just about what they were 
on the fourth floor. I have spoken since with some fire department people, who tell me that in smoke with 
fires it also sometimes can skip floors and the pattern of air distribution in a building is really not stacked 
up as you would think. Sometimes you do have a short circuit, so to speak, in the air flow pattern so that 
you can get a buildup in certain areas and not in others. 

But this I put up just to demonstrate that it is not just the second floor apartment. Ever since then, 
we now realize and we assume that if we find one contaminated apartment in a building, we assume that 
there is the potential for all the apartments in that building to be contaminated. 

This is an interesting piece of information. The toxics reporting in TRI data where the larger 
industries have to report their toxic releases, including perc, nationwide, reported about 16 million pounds 
emitted. Drycleaners don't have to report to the Toxics Release Inventory because they are small source 
generators. We have estimated based on a survey that we did in New York, that the aggregate of all the 
drycleaners in New York State emits approximately 13 million pounds of perc annually, compared to 
about 16 million pounds reported to TRI nationwide. So, I think that all of these small sources put 
together really represent an awful lot of release of perc in New York State. And I expect there would be 
similar numbers for the other states if such a survey were done. 

Just as a means of comparison, if you had perc in drinking water, 5 micrograms per liter is the 
maximum contaminant level. A person ingests about 2 liters a day. If you were to drink contaminated 
water at that level, you would be getting about 10 micrograms per day from drinking water. So, hold that 
thought. 


If you are living in one of these apartments and the apartment ranges are, let's say, a hundred to 
10,000 (which is probably somewhat conservative), you breathe about 20 cubic meters of air per day. So, 
you are getting from air from 2,000 to 200,000 of micrograms per day. Whereas, you would be only 
getting 10 micrograms per day from drinking water and your drinking water source would be closed by 
your regulatory agency in your state. 

So, just to put it in comparison, the levels that people are exposed to in these apartments are really 
quite high. There is a misconception that, if you can't smell it, there is not a problem. There is a number 
of things there. One is that drycleaners and others who are exposed to the high levels can get fatigued. 
Your sense of smell gets fatigued and you no longer recognize the smell whereas your neighbors might. 
People upstairs in your buildings might be able to smell it. 

Another misconception is that perc is denser than air and, therefore, won't escape the facility. We 
know that is not true. You have stairwells and elevator shafts. You have pipe chases. The hot water 
pipes that go up through apartment buildings have usually a little doughnut hole of space around the pipe 
and that acts as a very effective chimney and pulls the more contaminated air from the drycleaning 
facility up through the building. Sealing those pipe chases and other avenues of dispersal, therefore, is 
very important. 


18 


Yet another myth is that, if it is a problem, it is only in New York City. Again, it is just not so. I 
would like places like Chicago and L.A. and Washington and all of the older cities, all of the urban cities 
in the country to really take a look at where their drycleaners are. The EPA has done a lot, but it hasn't 
looked at that and it is something that we have been proposing now for awhile. The states really ought to 
be getting down to looking at where their drycleaners are located and how they can reduce exposure. 

Just to put this in perspective, you might ask, so why are you picking on us drycleaners anyway? 
We are hardworking small business people, which is true. How do they compare to other exposures? 
SuperFund often comes up. These are inactive hazardous waste sites. People are really worried about 
them. It has a high profile. 

Well, I will tell you that people living near hazardous waste sites, for perc, at least, are exposed to 
much, much less than people living in apartment buildings with operating drycleaners, without a doubt. 

In fact, the ATSDR, the health agency that looks at those sites, has established minimum risk levels for 
chronic exposure of 270 micrograms per cubic meter. Nearly every apartment we have measured in 
drycleaner buildings exceeds that number. If they were hazardous waste sites, it would be considered an 
urgent public health hazard, necessitating immediate action. So, there is a little dichotomy in how we 
look at hazardous waste sites and how we look at operating drycleaners, which we permit to operate in 
residential areas. 

I know I am running out of time and I am not going to get to my drycleaner study information. I 
recommend that you stop by the poster session, take a look at that yellow sheet, and come ask me if you 
have any particular questions. But, basically, we looked at six families living in two buildings in New 
York City, where there were operating drycleaners. And we took multiple air measurements in various 
rooms. We had the participants wear carbon absorber badges so we could measure their personal 
exposure and we also took blood samples, urine samples, breath samples, exhaled breath, and breast milk 
samples from two nursing mothers who were among the study participants. 

We also administered three vision tests as a way of evaluating neurological impacts on the visual 
system. To make a very long involved story very short, we found, as expected, high levels in each of the 
apartments—on the second floor, third floor, fourth floor, and sixth floor in these buildings. We found 
elevated biomarkers of dose in all of the study participants, including the children we examined, and we 
found an effect on vision indicative of neurological impact. 

Now, I would caution that it is a small study. It is a pilot study. We looked at 19 individuals, a 
small number of people. We hope to receive funding to do a larger study along these lines, a larger 
number of people and a wider array of neurological evaluation. Still, I think the results are important in 
that the levels of exposure for these people were roughly 0.1 to 1 part per million in the apartments. 

If we truly are seeing effects on vision at those levels of exposure, that notches down the degree 
to which you need to be exposed before you see an effect. That is an important finding if it is upheld on a 
larger study. So, I think it is something the drycleaning industry should really think about, and along with 
thinking about the importance of maintaining your equipment, keeping your solvent containers covered, 
doing all those kinds of things that are really important to minimize your own exposure and the exposure 
of your neighbors. 

Thank you. 


19 


Abstract for the Society of Toxicology Annual Meeting 

Judith S. Schreiber, Ph.D., presenter 

New York State Department of Health 

2 University Place Room 240 

Albany, New York 12203-3313 

March 3, 1998 

If you would like to receive a copy of the report on the study (completion date 4/98) leave 
your business card with Dr. Schreiber or send e-mail note to jss05@health.state.ny.us. 

ASSESSING RESIDENTIAL EXPOSURE TO TETRACHLOROETHENE USING 
BIOMARKERS AND VISUAL SYSTEM TESTING IN POPULATIONS LIVING ABOVE 
DRY CLEANING FACILITIES. J Schreiber. New York State Department of Health, Albany 
NY, K Hudnell USEPA, Research Triangle Park NC, J Parker, USEPA, Washington, D.C. 
Sponsor: L. Kaminsky . 

We conducted a pilot study to assess airborne exposure to tetrachloroethene and biomarkers of 
dose, and to evaluate visual system function in residents living above dry cleaning facilities using 
this solvent. The study population included 19 subjects (6 adult males, 7 adult females, 4 male 
children and 2 female children) who lived in two apartment buildings with operating dry cleaning 
facilities in New York City. Tetrachloroethene air concentrations were substantially elevated in 
all apartments above dry cleaners. Nearly all biomarkers of dose (tetrachloroethene in exhaled 
breath, urine, blood (adults only), and breastmilk (when available), and metabolites in urine) also 
were substantially elevated compared to background populations not living near dry cleaning 
facilities. Notably, analysis of some urine samples showed detectable levels of N-acetyl-S- 
(l,2,2-trichlorovinyl)-L-cysteine, a metabolite produced via glutathione conjugation. Metabolites 
produced via this pathway may play a role in the animal carcinogenicity of tetrachloroethene. 
Vision tests were administered to study subjects and to age-and gender-matched controls who did 
not live near dry cleaning facilities. Visual acuity did not differ between groups, but visual 
contrast sensitivity, an indicator of neurological function in the visual system, showed a strong 
significant group difference (F (16,144) = 19.38, p<0.001)). Color discrimination did not show a 
significant group difference, but there was a trend toward poorer color discrimination in the 
exposed subjects. 

(Note: This work was supported by USEPA Cooperative Agreement CR 824400-01 and the 
Strategic Environmental Research & Development Program. This abstract does not necessarily 
represent policies of USEPA, SERDP or NYSDOH). 

Key words: tetrachloroethene, biomarkers, neurotoxic effects 


H:\JSS\BIOMARK\SOT2.WPD 



ASSESSING RESIDENTIAL EXPOSURE TO TETRACHLOROETHENE 
USING BIOMARKERS AND VISUAL SYSTEM TESTING 
IN POPULATIONS LIVING ABOVE DRY CLEANING FACILITIES 

J. Schreiber 1 . K. Hudnell 2 , J. Parker 3 

*New York State Department of Health, Albany, N.Y. 

2 USEPA, RTPNC, 3 USEPA, Washington, DC, SponsorrL. Kaminsky 


HYPOTHESIS: 

■ Elevated perc levels in indoor air in residences above operating dry cleaning facilities 
cause elevated biomarkers of dose and neurological effects. 


STUDY DESIGN: 

■ We conducted a pilot study to assess airborne exposure to perc and biomarkers of dose 
breath, blood, urine, and breastmilk, and to evaluate visual system function in residents 
living above dry cleaning facilities in New York City. 


CONCLUSIONS: 

■ Elevated perc levels in air were found in all study apartments (n=6). 

■ Elevated perc biomarkers of dose were found in all study participants (n=19). 

■ N-acetyl-S-(l,2,2-trichIorovinyl)-L-cysteine was found in urine samples of some 
participants. This metabolite, produced via the glutathione conjugation pathway, may 
play a role in the animal carcinogenicity of perc. 

■ Visual acuity did not differ between study group and controls 

■ Contrast Sensitivity showed a strong significant group difference (p<0.001) 

■ Color discrimination did not show significant group differences, but there was a trend 
toward poorer color discrimination in the study group 


New York State Department of Health 
Perc Biomarker Study 
Preliminary Results, March 1998 


Family/Floor 

Sex 

Age 

Vision Test 

Tetrachloroethene Levels 

(range)* 

Contrast** 

Color*** 

Air 

Blood 

Breath 

Family 1 

2nd Floor 

Building A 

Male 

37 

4 

N 

25 - 3,900 

4.2-6.9 

28 - 2,600 

Female 

44 

4- 

4 

Female 

<1 

— 

— 

Family 2 

2nd Floor 

Building A 

Male 

34 

N 

N 

65-7,250 

4.3-43 

3-2,000 

Female 

36 

4 

4 

Male 

<1 

— 

— 

Family 3 

3rd Floor 

Building B 

Male 

37 

4 

4 

65- 1,200 

2.6-6.0 

6-230 

Female 

36 

4 

N 

Male 

6 

N 

4 

Male 

3 

— 

— 

Family 4 

4th Floor 

Building B 

Male 

72 

4 

4 

40 - 3,450 

5.4-6.7 

5-900 

Female 

44 

4 

N 

Female 

<2 

— 

— 

Family 5 

4th Floor 

Building B 

Male 

41 

N 

N 

140-2,000 

0.8- 1.3 

8.8-519 

Female 

39 

N 

N 

Female 

8 

4 

4 

Male 

6 

4 

4 

Family 6 

6th Floor 

Building B 

Male 

62 

4 

4 

30 - 700 

1.3-8.6 

9.4-290 

Female 

46 

N 

N 

Female 

20 

N 

N 

Male 

13 

4 

4 

Female 

3 

— 

— 


* Air = micrograms per cubic meter, Blood = micrograms per liter, Breath = micrograms per cubic meter 
** Visual Constrast Sensitivity 

* * * Color Discrimination 


4* = Below the normal range of responses 
N = Normal range of responses 


H:\EJP\BI0MARK\SUMTAJB2.WPD 




































DEFINITIONS AND ABBREVIATIONS 


CONTRAST = Visual contrast sensitivity measures neurological function in the visual system 
by measuring the ability to see faint wavy lines at certain spatial frequencies. (Vistech 
6001 VCTS; Stereo Optical Co.; Chicago, EL) 

COLOR = Color discrimination measures neurological function in the visual system by 
measuring the ability to place 15 color chips in the correct order. (Lanthony’s 
Desaturated 15 Hue Test according to Famsworth-Munsell; Luneau Ophthalmology; 
Paris, France) 

N = Normal range of responses 

= Below the normal range of responses 

mcg/m 3 = micrograms per cubic meter 

mcg/liter = microgams per liter 


We gratefully acknowledge the assistance of: 

Dr. Wolfgang Dekant of the University of Wurzberg, Germany, for urinary metabolite 
analysis. 

Dr. Andrew Geller of USEPA for vision assessment. 

Dr. David Ashley of CDC for blood analyses 

Dr. Kenneth Aldous of NYSDOH for air and biomarker analyses. 

Ms. Bettsy Prohonic and Ms. Karyn Langguth of NYSDOH for data analysis and 
presentation. 



LOG VISUAL CONTRAST SENSITIVITY 


CONTRAST 

SENSITIVITY 

TEST 


RESIDENTIAL PERC EXPOSURE 

160 
80 
40 
20 

10 


LOG SPATIAL FREQUENCY (CPD) 



1.5 3 6 12 18 


Hudnell, K., 1997 








CUMULATIVE PERCENTAGE 


COLOR 

DISCRIMINATION 

TEST 



1 2 
COLOR CONFUSION INDEX 


Geller, 1997, USEPA 









NYC Perc Biomarker Pilot Study 


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H:\KWL\PERC\NYCPERCB.DOC 


















Standardization and Testing 


Norma Keyes 

American Association of Textile Chemists and Colorists 

Norma Keyes is currently the Director of Fiber Quality Research at Cotton Incorporated. 
She has been an ASTM Member since 1989, serving on subcommittees for Fabric 
Performance Specifications, Yam Test Methods, Care Labeling, and Chemical and 
Conditioning Standards. 


My part of the conference today is talking about standardization and test methodology. 

This is a slide that Cindy Stroup used in February at AATCC meetings to give the concept of the 
EPA's Design for the Environment. I wanted to show it again to get us focused because part of the 
stakeholder part of this initiative really affects the textile industry. I tried to summarize again a little bit 
of that concept by listing some of the aspects of the textile industry of which this is a significant part or 
significant concern 

Now, we are talking about products for consumers and we are talking about the garment part of 
the garments and textile items. What are consumers concerned about? They are concerned about whether 
the color is going to be in it when they wash it. This is specific to home washing or home laundering. 
They want to know if the color is going to be in it. Are the parts going to be the same color? Is the white 
part of it going to be white when I get through washing it? Is the garment going to fit? Are the seams and 
the buttons and the tnms going to stay intact when I wash it and clean it? Does it look and smell clean? 

These are our basic concerns as consumers, not much different from what we expect when we go 
to the drycleaning of our textile items. The same things are of concern. Color. Fit. How does it look? 
How does it fit? Does it smell clean? Does it look clean? 

But you notice on the bottom of that list, I have added something and that is cost. That is the 
other element. It is not seen so much as a big deal when we expect to wash and care for something at 
home, but when we take it out to professional garment care people, cost is an issue. We haven't had too 
many complaints about drycleaning cost. 

Now, if we move this on to consumers' expectations for new technologies, that list really isn't 
going to change at all either. Those same things are going to be of concern. And I left cost on there, too, 
because we are still concerned about that aspect down the road, too. 

Now, how does the textile industry translate those concepts into our language? Well, our 
language is colorfastness, change of color, bleeding, staining, dimensional change, appearance. Well, 
what do we do with that? What kind of language? And that transfers into standards and test methodology 
development. 

That is how the textile industry deals with this. We do it with the consensus process. We have 
interested parties come together and discuss a topic and decide how we are going to test for this property 
of change of color or bleeding or staining or whatever it is. The consensus process is very important 
because, when a test method gets to the standard stage and gets approval, that is the way we analyze it. 


20 



ASTM's focus is on standards and test methods relates to performance specifications and to basic 
properties, such as tensile properties and tear and those aspects. Also, care labeling and symbols has 
come under the auspices of ASTM. 

In AATCC, our focus is on test methods for the wet processing part of the textile chain. Now, I 
am going to spend a lot of time on ASTM and AATCC, but I want to mention that the specifications for 
performance related to drycleaning, are based usually on AATCC test methods. 

The AATCC's test methods for garment care relate to home laundering and drycleaning, and we 
have some test methods that predict commercial laundering performance. 

Now, the test methods that are related to drycleaning were developed with perc coming into the 
drycleaning process. Some of those have dates of 1950s, late 1950s and sixties. So, these standards and 
test methods are a direct result of what was happening to the laundering care product area at that time. 
Some of these are not in widespread use at this time. Test Method 86 is used. Test Methods 132, the 
colorfastness to drycleaning, and 158 are somewhat used. People may have different perspectives on that 
but it is normal. 

The other aspect of what AATCC does is to help users have evaluation techniques and these are 
called evaluation procedures. These are not only used here in the United States but many of these are also 
used in the international arena. 

So, you can see gray scale for change of color, for staining. There are instrumental assessments 
for change of color and then the nine step chromatic scale. Now, when perc got to be an ugly word, some 
testing laboratories had to make some decisions on how to deal with perc. Many times, their facilities 
couldn't handle it or chose not to so sometimes testing laboratories choose to just use local drycleaners for 
some of these evaluations. That is not a standard approach and it is not an official test method, but it is a 
matter of not having to deal with perc in the testing laboratory arena. 

Recognize that there are some other approaches to looking at drycleaning performance. Now, 
many of the ASTM standards are related to performance after drycleaning. I guess you didn't realize how 
important zippers were in the drycleaning process and that there could be a dramatic effect. There 
happened to be two standards in ASTM related to zipper performance in drycleanmg. There are other 
ASTM standards that have references to drycleaning performance. 

Other references to drycleaning and the textile care chain related to ASTM activity are care 
instructions. Many of these care instructions relate in terminology and the care symbols. We have to 
have a symbol for drycleaning and that is going to come up, I think, later in the conference. Connie is 
going to be talking about care labels and symbols and, you know, we are going to have to have a symbol 
for wetcleaning, whatever wetcleaning is. 

And there is the question. What is wetcleaning? Well, you know, you might be surprised that we 
haven't defined wetcleaning yet. We don't know how it is going to fall out. It may be one or two or three 
different things. It may be combinations of processes. 

I hope we define it because it certainly is a concern to the textile industry. There is a definition 
here and you can see a date on that, 1945, by Norbert Berg. Some of you may know this gentleman. I 


21 


don't know him, but he had a definition for wetcleaning in 1945. This was published last month in the 
Fabricare Resources Bulletin that is put out by IFI. 

I think that definition really is pretty comprehensive. He went on a little bit and expanded on that 
concept, but that definition may cover things. When we get to AATCC and new test method 
developments, you had better believe we will be defining "wetcleaning." 

Now, how many emerging technologies are there going to be? Can current test methods be 
adapted to predict wetcleaning performance? We don't know that. Will new test standards need to be 
developed? I would probably say "yes." It is probably a foregone conclusion that we are going to have to 
do some new test methods or are we going to have new equipment in the laboratory to do this. I would 
say maybe we can adapt some things. 

When do we need to start working on this for developing test methods? Well, we can't do that 
until somebody decides what is going to be out there in the care process. There is the old launderometer, 
the tried and true; it has been with us a long time and has been used widely. There are things coming 
along in the home washing area maybe that could help us. 

Front loading technology is coming along with less water usage, less agitation. Is there 
something we can do with home laundering equipment? There is other new equipment that is coming 
along to predict shrinkage. Maybe that can be adapted and used. 

But AATCC is prepared to help the textile industry with its garment care processing and where 
we are going with that. We have reactivated the drycleaning committee. It is considering changing its 
title and scope and has balloted a new title and scope. 

Here is what the Drycleaning Test Method Committee's scope is currently. It was changed to 
Professional Textile Care Test Methods. That is a big comprehensive title. The scope has been reworded 
a little bit to handle this new title and we think AATCC is prepared to deal with the future emerging 
technologies. 

Now, the AATCC is set up to do this. There is a development process for test methods and 
standards. Somebody has to say, there is a need for it. It can be an individual. It can be a company. It 
doesn't have to be an AATCC member. It can be an association of drycleaning cooperatives. It could be 
anyone who says we think there is a need for this. Present information for it. Once that need is 
established, then we decide if it fits under a scope of a committee. Well, right now garment care is related 
to drycleaning and it already has a committee that addresses it. 

Then we go on to some other development stages and it goes through a whole process of studies 
and test method development and balloting process. That is how the standardization and test method 
process works. Once it is published, it is official. 

Let me just mention, too, that Manfred Wentz is the chairman of the AATCC Drycleaning 
Committee and we will be depending on his leadership. Let me also just briefly mention that in the ISO 
arena for textiles that there are several working groups that are associated with drycleaning. In the 
Subcommittee for Cleansing, Finishing and Water Resistance there is a Drycleaning Working Group. 


22 


I wanted to show you the spectrum of subcommittees for drycleaning, finishing, washing, 
appearance, durability, flame retardant fmishes, tumble drying, water resistance, and industrial washing. 
In ISO there is also a standardization process in place. These four documents are in the standardization 
process in ISO and the USA's position on these has been positive. You can see a time line for that in 
1997. Parts 1 and 2 were at draft international standards stage and Part 3 and 4 are coming along in ISO 
development Stage 2. 

So, to wrap it up, the AATCC is ready to help the textile industry meet the challenge of the 
changing and emerging technologies in garment and textile care. 


23 


The Opportunity for Transitions Planning in the Fabricare Industry 

David DeRosa 
Greenpeace 

David DeRosa has worked for Greenpeace for over 10 years. He is a toxics campaigner 
for Greenpeace USA, working on the substitution of chlorinated solvents in drycleaning. 


Hello. My name is David DeRosa, and I work for the Greenpeace toxics campaign. I'm here to 
talk about transition planning—the process of maximizing changes in industrial processes for what we 
call stakeholders, such as workers and small business owners, when solving environmental problems. As 
our keynote speaker, Ed Barlow, noted this morning, change is inevitable. This conference is going to 
convey a lot of technical information and a lot of elaborate mechanisms for dealing with change, so it's 
good to start with the basics: change is coming, it's here, it happens every day. The public deals with 
changes in ways the don't even know they're doing. As a provider of a public service, the drycleaning 
industry has to be ready for changes, and able to make them as seamlessly as possible. Satisfying 
people's need for convenience is the key, and exposing our customers to toxic chemicals is, on many 
levels, a bit inconvenient for many people. That is what transition planning strives to make possible. 
Business books may tell us to "thrive on chaos," but most people would like to know ahead of time which 
mechanisms they can depend on when they must change. Just because change happens doesn't mean it 
must happen in an uncontrolled fashion. As Mr. Barlow put it, "we must work smarter as well as harder." 

So change should not be feared, but relied upon. Without change, for instance, there would be no 
fashion industry because everyone would wear the same clothes for years. Then where would the 
fabricare business be? But, to set up an extended metaphor, there comes a time when change strikes at 
the heart of how you define yourself, when your old clothes (that you know and love) cannot be used any 
more. But to get into your new clothes, you must commit to takmg the old ones off, which leaves you 
vulnerable—even naked—for a little while. Some want to jump into their new clothes; others want to go 
gradually, perhaps getting a new shirt on before the old pants come off. Sensible enough. But still others 
will want to explain that the old clothes are fine, that there's no reason to waste money on new clothes, or 
that if they wait long enough with the ragged clothes on their backs, they'll come back into fashion. This 
defensive posture can take many forms; some figure, if I add a new pair of fancy shoes, no one will notice 
my old-fashioned clothes. Or by spraying enough cologne, I can cover the smell. These are rationales 
from people afraid to face the truth, get the change over with, and settle in. 

What do you do when the way you make your living becomes undoable? In today's modem 
world, this is a prime question faced by people the world over. In an extreme example, people who 
weave baskets or make handicrafts all over the third world are finding their job skills no longer needed, as 
they can be "better" made by machinery. Closer to home, those who made buggy whips and carriages 
found that they went out of work when automobiles wiped out the previous dominant mode of transport. 
More recently, workers who make products that should no longer to be made are finding that their very 
good paying jobs in pesticides or plastics factories are being scheduled for phaseout. Many are 
represented by unions, which do not exist to put workers out of business. So instead they must find a way 
to train their workers for more sustainable and appropriate work. 

Why is there a resistance to transition planning? For some, a denial of the problem; for others, a 
doubt that any assistance would be forthcoming, forcing that defensive posture. One thing is sure: those 


24 


who would like to help will only be able for so long. We attempted, through the Professional 
WetCleaners Partnership, to find an amicable solution for an orderly phaseout for one of the most at nsk 
groups: co-located cleaners in New York City. Faced with new state regs, potential action on a city level, 
and a lawsuit going through the courts that challenges disproportionate zoning, these are cleaners facing 
huge challenges to their survival. Cleaners may fairly suspect the motives of those who would help them; 
Greenpeace can only say that we would like to be able to point to a transition of this industry as a model 
for how industry can make the changes it needs. Without regulatory requirements, no one can make the 
industry change; yet change is coming, and the question that most needs asking is how smooth it can be, 
and how much the face of the industry will change. Orderly timetables can most easily be imposed on a 
phaseout; when there is disagreement on what the endpoint is, timing becomes chaotic, and helpful 
mechanisms of funding and training may disappear or go unused. 

Let me ask a question: How far into the future will perc be used? Let me ask a knowledgeable 
crowd. Raise your hand if you think perc will still be used in the cleaning profession five years from 
now. OK, how about ten years from now? Fifty years? One hundred? As you could see, fewer hands 
each round, but some die-hards never took their hands down. Many people would like to believe that perc 
will be around until their shop closes, or "let the kids deal with it." I'm here to tell you that that attitude 
won't work. Besides what EPA and OSHA and other federal agencies are doing, you should know that 
the UN is negotiating a treaty to phase out sources of long-range pollutants, such as dioxin, which is 
produced in the manufacture and disposal of perc. So even if you solve all your exposure problems in 
your shop, the actual manufacture of perc, for which most of you are not to blame, may be too dirty to 
continue. Then its gone: So maybe you should drop them before they drop you. It needn't be sudden, 
tomorrow, but you need to plan. 

I have met some cleaners who seem to think that Greenpeace wants to see ever more arcane 
regulations monitoring perc levels down to some vanishing small level, like parts per "zillion" or as low 
as the detecting devices can go. But I think we want the same thing many cleaners want: a cleaning 
method so clean it doesn't require that kind of regulation. Dr. Wentz said, earlier, that there are many 
different ways you can move toward reducing toxic exposures. That's true. But even if a whole 
generation of cleaners moves toward fifth generation machines, someone, someday will buy the last perc 
machine, just as someone bought the last buggy whip. Certainly no one would wish to see cleaners 
switch to a care method that ignores what customers need for their garments. Yet cleaners must also not 
trap themselves into denying that other methods can work, and even that to some extent as fabricare 
changes in this country, clothes will change to reflect that. 

Environmentalist have always joked that we are working to put ourselves out of a job— 
unfortunately, right now there is no shortage of ecological risks, so we're in no danger yet. Before we 
face joblessness, we are dealing with other industries facing the problem of working themselves out of 
their jobs, like whaling, or logging. Greenpeace's toxics campaign works on the chemical industry based 
on chlorine, which is used to make perc It's also used to make many pesticides, many of which are found 
to be dangerous. Production gets phased out, which means that good-paying jobs disappear. We are 
working with unions and the chemical industry to adjust that process so it happens in an orderly way. 

This isn't just out of the goodness of our hearts, it would also help us get dangerous products off the 
market faster. We want to help retrain these people for new productive work, and find the money to do it, 
whether by taxing the products they make or in other ways. 

Drycleaning is different, of course, because it is a service industry, and customers don't care what 
you use as long as it works. As industry leader Bill Seitz has often stated, "Cleaners aren't wedded to 


25 


perc." That's good, but begs the question of how messy the breakup is going to be. We would like to 
treat this conference as a turning point. The last couple of years have been an important testing ground: 
Phase 1 for wetcleaning. You will be hearing, at this conference, results showing that wetcleaning works. 
And we will be hearing from other emerging technologies that could have strong points where 
wetcleaning might have weak points. So the proving is over, and the implementing must begin. 

The question is what we as stakeholders can do to make this as easy as possible, while keeping 
the industry as prosperous as possible. We need incentives set up that can "front load" the changes so that 
change isn't put off till the last possible minute, and we need to find out what other components, such as 
training, or tax breaks, or whatever, need to be in place. Then, when there is confidence in the 
alternatives, and an understanding of the feasibility of switching, we can setup a phase out plan so that 
everyone has a deadline. 

We all want to see cleaners using clean technology that cannot, even with massive machinery or 
operator failure, cause any harm to the environment or human health. When there is no alternative to a 
dirty technology, it may be considered a necessary evil; when such alternatives do exist, there must be a 
common goal of finding a good way to those new methods. 

I work on the Drycleaning Advisory Committee for the New York State Department of 
Environmental Conservation with the trade associations, UNITE, Consumers Union, and other 
stakeholders. It has been really instructive to see how drycleaners get certified, how equipment is 
approved, and how regular inspections can serve to give the public confidence in professional cleaning. I 
don't know a people more dependent on drycleaning services than New Yorkers, but there is a growing 
awareness that there is risk involved. And there are so many hoops to jump through. More expensive 
machines to buy, vapor bamers to install—it's what I call an "upgrade treadmill", because every upgrade 
costs more, so it's like walkmg in place up a steep incline. Running to stand still. Forcing an industry to 
spend significant amounts of money to come into compliance with current regulations, only to impose 
new regulations before that previous compliance machinery has reached the end of its usefulness, is not 
good policy. And in the meantime certain towns in New York are not allowing new perc cleaners at all. 

So New York is looking into making grant money available for problematic cleaners to get other 
equipment, and outreach methods. The time is coming when people will be looking for clean cleaners, 
and they'll know what other quality they want beside price and speed. 

Certain obstacles to change will not go away with new care methods; in particular, retroactive 
liability will remain from past contamination even after the process changes. Greenpeace is willing to 
explore methods of lessening liability as part of a transition plan, but this must never come at the expense 
of needed cleanup. The public would never countenance such a buy-off. However, there are mechanisms 
that might help move existing cleaners to non-polluting methods with a means of capping liability, or 
perhaps transferring it to other, more responsible parties. We do not want to see perc-based liabilities 
keep cleaners from switches they would otherwise have made simply because switching makes it look as 
though they're guilty. But no such mechanisms can be negotiated until the need for transition is admitted. 

We have talked with industry; trade associations such as IFI and NCA have worked with us in the 
PWCP to find mechanisms for change. We have not always agreed on where the end-points should be, or 
how fast change should happen, but we all saw that the industry is changing and wanted to use that 
change to help the industry. We all have our biases, but must seek to understand each other how each 
other benefits from change that works. Greenpeace has no stake in any cleaning technology; early on we 
championed wetcleaning, as it was the only one the fit our criteria for a solution; as others come on the 


26 


market, they too will be studied. Cleaners need help distinguishing among many methods, including all 
types of wet cleaning, other existing solvent technologies, and new emerging technologies that are just 
over the horizon. This is what cleaners look to their trade leaders for: leadership. (They may not look to 
regulators for more regulation, but clear criteria certainly help them decide which alternatives meet their 
needs.) A workable transition plan can start with a certain high-profile group, such as the co-located 
cleaners being studied in New York and elsewhere, but the lessons learned will be applicable to the whole 
country. Even now, various states such as Oregon, Minnesota, and Florida have developed different ways 
to help cleaners prioritize the decisions they need to make. OSHA's pending PEL, further EPA 
regulation, and changes to Superfund will do that even more. 

As part of the program that led to this conference, EPA is planning to issue a document assessing 
different technologies that will help the trade associations help their members. While not regulatory in 
scope, it will start a dialogue on what transition opportunities exist. It will make it clear to cleaners that 
perc has an effect on their health—in fact, they're more affected by it than almost any other sector of 
society, though we are growing our understanding of how it affects customers, and people living upstairs, 
and event hose who live near where perc is made. Of course, among the cleaners, many have known for 
years it was affecting them somehow, but weren't able to admit it to themselves. In a successful business, 
they figure "There are always trade-offs", and besides, they couldn't be sure. There are plenty of healthy 
cleaners out there, right? Anecdotal evidence always makes it harder to understand risk. You may be 
healthy, you may not—but it's too late by the time you find out. 

Instead, Greenpeace wants to help cleaners find out how to make this change work for them. The 
same way that you feel most vulnerable when you're changing your clothes, cleaners feel vulnerable 
changing processes. Any cleaners represented here today are likely to be larger, better capitalized 
shops—the kind that can take weekdays off. Most cleaners, as you all know, are smaller shops, most with 
only one main cleaning machine, usually perc. For them to switch, they need to know that it'll work, that 
they can afford it, that the public will want it, and ideally that garment companies will make clothes into 
the future that respond well to that process. Which is the reason for the industrial ecology approach of 
this EPA program, since it is helpful to the whole process to get the garment and textile companies 
involved if garment care processes are to change. Meanwhile, you bigger shops with more than one 
cleaning machine are the ones that can do the experimenting with carbon dioxide, glycol ethers, 
ultrasonics, and anything else that comes along. The development of all these different alternative 
processes is proof that we may not soon go back to having a major dominant solvent, as perc is now. 

That's fine—if for no other reason than to force the consumer to become more educated about options for 
fabncare they have. 

This conference is by no means the end of this process. The stakeholder process is organizing 
workgroups that will extend various key efforts to making any transition work. Greenpeace has always 
been a bit dubious of "voluntary compliance" programs, though DfE has gotten some major changes in 
other industries it has worked on. What it hasn't done is show an industry how to get past the expensive 
control technologies and find a way out of government scrutiny and into clean processes. That's where 
the workgroups come in. To work, they must find creative ways to communicate that these alternatives 
work. That's the good news. When this campaign started five years ago, the only replacements to perc 
were other problematic solvents like CFCs and Stoddard solvents. Wetcleaning was being studied as an 
adjunct, but there was a lot of sensible doubt as to whether I could replace perc. 

That doubt should be dispelled by now. Shops are doing 100% wetcleaning in this country, and 
getting fme results. We do seem to keep getting results from some professional groups showing that 


27 


certain wools and other fabrics kept shrinking. Certainly a danger, but it scares me that the pros can't get 
it right. Maybe they're not trying hard enough; when the FCRA allowed a trained professional to work at 
their own pace in a side-by-side test last year, difficult garments were wetcleaned fine. But this fact does 
show that one of the most important things to be developed is a standardized test method, a first step on 
the way to more environmentally sound care labeling, about which we will hear more from the FTC later. 

The main stumbling block to coherent transition planning is forethought. Other obstacles, such as 
training and incentive moneys, can be found if those who might support the planned endpoint know that it 
will happen. I've seen, even in the big trade associations, a fear that no money can be available, that no 
one wants to help beleaguered small businesses. That thought is a self-fulfilling prophecy. There is an 
enormous sympathy for "Mom and Pop" businesses such as drycleaners, one that will last until the public 
fears you are poisoning them out of ignorance and defensiveness. The former can't be helped; the latter is 
a crime they won't forgive. 

We know from big cities like New York that people like the convenience of having cleaners in 
their buildings. We also are learning that perc just doesn't belong in residential buildings, near food 
centers, or in otherwise crowded locations. If you honestly think your best option is shopping for 
containment pans, floor sealants, filtered ventilation fans, and other very expensive control technology, 
well, all we can say is that it's your decision. For now. But if you look closely at inherently safe 
technologies like water and CO 2 , or becoming a drop shop and picking and choosing which methods are 
used, you may be being more honest with yourself. 

No one can make the cleaners face their problems. There is a fine line involved, where public 
pressure can help cleaners make such decisions, but too much can push customers away from cleaners, 
which does not help them prosper. The more there is a united front from stakeholders on the need for a 
transition, the less chance there is to exert too much pressure. We may disagree on certain things— 
Greenpeace has its biases, though we don't stand to make money on whichever process comes out on 
top—but we can all come together to find a better understanding of what will keep the cleaning industry 
viable into the 21 st century. Ken Adamson, a forward-thinking cleaner, has said that the cleaner of the 
future will need to know two things: water and something else. This is solutions-oriented honesty. One 
thing I can tell you won't help is a defensive outlook. When you circle the wagons, all you get is circular 
thinking. 


28 


Industrial Ecology and the Garment Care Industry 


Joseph J. Breen, Ph.D. 

The Green Chemistry Institute 
Rockville, MD 20850 
breenj l@westat.com 

Dr. Breen currently serves as Executive Director for the Green Chemistry Institute. He is 
retired from the U.S. EPA's Office of Pollution Prevention and Toxics after 23 years of 
Federal service. During his tenure at EPA, he served as chief of the Industrial Chemistry 
Branch and the Design for the Environment Program. 


The garment care industry faces senous challenges as it leaves the 20th and moves into the 21st 
century. Several significant forces are shaping the future of the business landscape: increasing regulatory 
controls as a result of societal demands for improved environmental performance, market demands for 
increased profitability and productivity, higher customer expectations, and changing employee 
requirements. How the industry meets these challenges will affect the economic viability of the thirty 
thousand garment care shops across the country. 

To put these challenges into perspective, I would like to discuss with you the systems approach, 
called industrial ecology, that is being considered as a new paradigm for domg business in the future. In 
Figure 1, taken from the President’s Council for Sustainable Development (PCSD), we see the PCSD’s 
attempt to forecast a 50 year time line as to where society wants to be in the year 2040. The intent is to 
inform us on how we should be expending our limited and diminishing resources from 1990 to 2040 in 
terms of remediation, monitoring, controls, and avoidance or pollution prevention.. 

We see from the Figure, that in the late 1990s, the level of effort we are expanding is 
characterized by no particular set of priorities. Pollution prevention, remediation, control and monitoring 
all seem to be equally important. It is evidence of a chaotic state where we throw our money at whatever 
is the ‘crisis of the day, week, or month. This late 90's performance is contrasted with the plan to have 
most of our efforts in 2040 focused on pollution prevention, with minimal resources committed to 
remediation. I say minimal in that we will always have some expenditures of dealing with the historical 
waste sites and spill that can reasonable be expected to occur in the best of times. 

In the 21st century, the message will be clear, we will want to be expending most of our effort on 
pollution prevention. If we can do it in such a way that we do not bear the cross of liability and 
compliance costs, all the better. What does this mean for the garment care industry? It turns out, as 
illustrated by the cartoon (Figure 2) that the fabncare industry is only a part of a larger interconnecting 
web of activities that make up the overall garment industry. That industry extends from fiber production 
through textile and garment fabrication to the final care by the fabncare professional. As we learn how to 
do business in a more environmentally sound manner and promote cleaner garment care technologies, we 
realize we must include them in the process. If they are to provide us with the garments amenable to the 
use of more environmentally benign technologies, then we must inform them of what our requirements 
are in terms of garment characteristics. We must coordinate our efforts with all of the industries back up 
the production line network. 


29 


The fabricare industry must serve as the central impetus to the technological pull on the providers 
of garment care technology as indicated at the bottom of the cartoon. Fabricare professionals accomplish 
this by demanding an environmentally benign way of doing business in their shops. You provide the 
market demand on the hardware and chemical distributors, who in turn express your requirements to the 
technology developers and hardware manufacturers. You must also engage the fabricators of the garments 
themselves, expressing your requirement to have garments that are amenable to proper care using 
environmentally benign processes. 

This prompts the garment producer to tug on the fabric manufacturers to construct fabncs to meet 
the new requirements, who in turn pressure the fiber manufacturers to articulate new specifications for 
fibers that will meet not only the usual fabric performance and styling parameters but also the care 
requirements. To effect such a change would represent a highly successful 'technological puli' on the 
system. 


The cartoon also indicates a complementary approach to the technological pull on the system. 
This is illustrated by EPA’s companion program, Green Chemistry, that provides the technological push 
to the fiber producers. Chemists develop, at the molecular level, the fibers that are converted into the 
polymers that are converted into the textiles. They are developing ways of learning how we do those 
things in a way that is also environmentally benign, so that you are producing polymers and textiles in a 
more environmentally benign way. 

Earlier today, I picked up on something that the keynote speaker talked about as a systems 
approach, where 1 plus 1 is 3. In other words, there is a synergistic effect of people rowing together in 
the same direction. We need to understand that garment and textile care is only one part of a complex 
network of business and societal relationships and that technology and practice changes in professional 
cleaning need to be understood in that broader context. 

In fact, here is a graphic depicting the synergistic arithmetic for the garment care case. It is in 
the larger context of how you go from the chemist making the fibers and the polymers, all the way 
through the system of garment manufacturers and the distribution and fabncare system. 

The EPA DfE Program provides information on product and process design for sustain ability and 
clean production and pollution prevention. We need these technological tools in order to do properly 
compare out options. The goal, from the industrial ecology perspective for the garment and textile care 
program, is to understand the complex interplay of the economic forces. In the final analysis, our choices 
of technology must be profitable for them to be economically viable. 

The real challenge in this for all of us is the consumer. We must aggressively and intelligently 
build up consumer demand for environmentally benign processes. If we are to have garments produced 
with environmentally benign processes, we will need to use this industrial ecology framework to facilitate 
implementation through the stakeholder process EPA has in place. We will need to engage all of the 
leaders from the industries beyond the fabricare professional. For the skeptics, may I suggest to you that 
some of this is here today. Right now. Let me provide a real-world example. 

This Figure is from the back of the product brochure for the William McDonough Collection. It 
is the fabric that is used in upholstery for chairs in the new Ronald Reagan Building in Washington, DC. 
This is an interesting story of taking a mixture of safe, pesticide-free plant and animal fibers for the fabric 
(ramie and wool) that at the end of its useful life was to be combustible, i.e., would decompose naturally. 


30 


Sixty chemical companies were approached to work on developing the chemical finishes for the fabric - 
all declined. Finally, Ciba - Geigy agreed to work on the project. After considering some 8,000 
chemicals used in the textile industry, they eliminated 7,962 as being problematic. The fabric ended up 
being created using only 38 chemicals. The director of the textile mill reported the amusing anecdote of 
having the regulatory agency finding that the effluent from the mill was as clean as the influent into the 
mill. This is a real-world example of a textile product line being marketed by Design Tex. 

There are other industry leaders of technological change close to the area of fabricare that are 
present here at the workshop. The prestigious R&D 100 Award was won by Global Technologies and 
Hughes Environmental on the one hand, and the prestigious Presidential Green Chemistry Challenge 
Award being won by MiCELL Technologies on the other hand. 

This month's issue of ACS's ChemTech has several relevant articles. One is on impregnating 
porous solids using liquid CO 2 . It describes how to get a chemical into the fiber or into the porous solid. 
This relates to the issue of how to dye textiles with liquid carbon dioxide, without using chlorinated or 
aromatic solvents. This is the same technology proposed by others here in the workshop as a feasible 
technology for fabricare. 

The take home message is that we are not talking about some blue sky, theoretical possibility. It 
is happening real time, here and now. They represent green chemistry and engineering in 1998. The next 
Figure provides the critical building blocks for sustainable corporations in the 21st century that will 
provide the competitive edge in business over the next 25 years. 

The goal is zero waste through: emission and waste reduction; increased material energy and 
water use efficiencies; developing inherently safer products, processes and distribution systems; a 
reduction in the total system impact through design for the environment and life cycle analysis; and 
increased social value per unit of resource invested. Finally, in order to drive this whole process, it is 
imperative that significant shareholder value is created so that people will invest in these technologies. 

What are the kinds of technology we are talking about? They are listed on the next Figure. They 
are those that are characterized by: high yield; low waste process technology; converting byproducts from 
what was once waste; through reuse and recycle; getting to zero waste; and making the process inherently 
safer. 


Let us look at some illustrations: 

High Yield - Low Waste: DuPont Spandex fiber. They have improved their process through one- 
pass production and they have it now in some facilities where they have reached 99.8 percent. In one 
facility, the waste is so low that they have shut down their treatment plant, and arranged with the publicly- 
owned treatment works to accept their waste. 

Byproducts from What was Once Waste: Soil Amenders. DuPont in one facility generate large 
amounts of sulfuric acid. Now they neutralize the acid to create calcium sulfite pellets. The pellets are 
sold to peanut farmers as soil amenders. 

Reuse and recycling: Milk Jugs to Package Envelopes. A portion of the Tyvec polyolethane is 
now being recycled back to produce virtually indestructible envelopes. The interesting point here is they 
have figured out a way to improve the clean recyclability of polyethylene water and milk jugs and have 
now reused 200 million jugs, enough to stretch around the world - twice. It is also an illustration of where 


31 


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anse once a group of people with the objective for getting to zero waste are mobilized. 

Getting to ‘Zero Waste: Soil substitutes. DuPont at one facility generated a large amounts of iron 
chloride which they landfilled. With their zero waste policy, they found—that instead of landfills - they 
can place the iron chloride in a tank, treat it and then create another product called iron-rich, which is a 
soil substitute. They now have a revenue stream from what they used to consider a waste and landfilled. 
This illustrates the concept of atom economy, where every atom that goes into the process comes out as a 
product or a useful byproduct. 

Making it Inherently Safer: ROTIM. In terms of making waste inherently safer, there is ROTIM, 
the recycle or throw it in the mixer way of doing business. This is a process where you throw the 
neoprene monomer and the bag (made of a resin) in which the monomer is packed directly into the mixer. 
This eliminates occupational exposure to the monomer, and there is no packaging waste. Everything gets 
used. And there have been actual examples where the presence of that small amount of resin has actually 
improved the process and the performance of the product. 

Obviously, I get excited about these developments. This is green chemistry. There are a lot of 
things going on in this arena, some of them very directly applicable to the fiber, textile and garment care 
industries. EPA, as well as the Office of Industrial Technologies at DOE, are having a workshop in April 
on dense phase fluids, an alternative reaction media where applications to fabricare will be discussed. 

The University of Massachusetts is having a similar workshop in June on polymer R&D in green 
chemistry. We will be discussing how to make polymers for fabrics that will be suitable for green 
garment care. 

Green Chemistry is an international phenomenon. The First International Workshop on Green 
Chemistry in China will be held in May. We will be taking both Due and Green Chemistry materials 
there to educate participants on recent research and developments. A similar conference, the Mendeleev 
Chemical Technologies Conference in Russia, where, again, we will be taking the Due and Green 
Chemistry information to share with them on the garment and textile care process. 

The importance, as Ed Barlow made the point this morning, is that we need to generate 
international markets for these technologies in order for them to be economically cost competitive. We 
need to develop international global level systems so that the pnce of the liquid CO 2 technologies or the 
other environmentally benign technologies really becomes cost competitive as we develop the market for 
it. 


I hope I have persuaded you that you are participating in something that is both technically and 
economically exciting, and that it is important in terms of the way society does business. I am very 
hopeful that the outcome from the breakout sessions during this workshop will be a series of game plans 
to move forward in implementing an industrial ecology approach for the garment and textile care 
program. If successful, it will serve as a model for other industrial sector projects. 


32 


The Garment and Textile Care Program 
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A Cleaner’s Vision of the Future 


Buster Bell 

Bell Laundry and Cleaners 

Walter (Buster) Bell is a seasoned professional in the laundry and drycleaning business. 
He founded his first drycleaning business in 1954. He is actively involved with 
environmental certification efforts for perc and petroleum cleaners. 


We are talking about moving into new technologies for the industry but first, we have to reach the 
industry. At this time, we are able to reach possibly one-third of the industry. The associations are not 
able to reach the rest and neither is EPA. To get on with the future, we need a better method of reaching 
this segment of the industry to provide them with the necessary educational materials. The only way that 
I see that we can reach this segment of the industry is through meaningful certification programs and the 
actual certification of certain pieces of equipment, requirements within plants themselves and of the 
cleaners. 

The certification should include the participation of both Greenpeace and OSHA. In other words, 
the industry and the regulatory agencies need to mesh. We don't need to be at odds with each other. We 
need to find solutions to get this segment of the industry to the tables. We need certification programs 
that include floor coverings and containment tanks. We need to do away with things like small generator 
classification and transfer equipment. All these things are in the past and we need to move on. 

We need to find a method that is enforceable and manageable. Part of that process would tie the 
cleaner doing these certifications and certification on equipment, floor coverings, and things of this nature 
to the purchase of solvents. In this manner, we can bring forward new technologies and stop continuous 
contamination now, which is very important to all of us. 

The only way is to tie all this together is through the purchase of solvents. Without this, we are 
not going to reach two-thirds of the cleaners out there to educate them, to teach them what wetcleaning is, 
what carbon dioxide is. 

In South Carolina we passed legislation creating an environmental trust fund for ground water 
contamination. We put rules in to stop continuous contamination. But we made one mistake. We should 
have tied it back so that these things were done by solvent. Right now, we are going to have to run on an 
amnesty program because 50 percent of the cleaners did not take their certification, did not put 
containment tanks in, or did not even attempt to purchase third party liability insurance. 

The legislation was put there to protect the cleaner. Last week, I had a cleaner call me. "I am in a 
world of hurt, I am going to lose everything I have. I can salvage my home if I can sell my business. I 
am not in the fund. Nobody will buy this business from me," he said. 

So, he would have to go back—we will have to run an amnesty program through the state 
legislation to bring these people in after they finally meet the qualifications. But if you tie all this back to 
his ability to buy his solvent, you will get his attention. You will get him to where he will attend 
meetings, he will leam, or else he will decide he doesn't want to be in business. 


33 


We need workable solutions. At this time, this, I think, is one of the most workable solutions we 
can up with to reach two-thirds of these cleaners. 


34 


Introducing Customers to New Cleaning Processes 


Ed Boorstein 
Prestige Cleaners 

Edward B. Boorstein has been an owner-operator of drycleaning businesses and plants 

since 1951. Over the years he has had as many as 13 locations, but currently all of his 

focus is on Prestige.. .Exceptional Fabncare. 

At your seats you have some examples of some of the educational initiatives my company has 
undertaken to introduce wetcleanmg and our particular focus on people who have chemical sensitivities. I 
am going to speak about introducing the public to new professional fabncare processes and I am going to 
ask you to bear with me because I want to read this. I don't think I could speak extemporaneously and get 
all these thoughts to you, so I have organized them. 

One of the most successful, seamless, low tech point of sale campaigns to alter public 
consumption habits is the supermarket checkout question, "paper or plastic?" Notice, that true to the 
tenets of suggestive selling, plastic has the final word, has the best chance of having the most impact. 

I bet that most grocenes leave the market in plastic bags. What if every fabncare professional 
offered every customer the at-the-counter choice, "dryclean or wetclean?" Notice that wetclean is the 
final word. I bet that public understanding of this new process, wetcleaning, would be assured faster than 
you could say drink Coca-Cola. But I believe that this is an unlikely scenano. 

There are inherent risks in pioneenng a stance and a mynad of interrelated impediments to a bold 
courting of wetcleaning business, many of which are beyond the ability of the professional cleaner to 
overcome. Wetcleaning is as old as the river and as new as today and now is the only fully realized 
fabricare alternative to petrochemical immersion. 

The acceptance of wetcleaning is limited first by public perception. Mention water and the 
immediate customer response is likely to be, oh, I will wash it at home then. The average cleaner's 
inability to articulate as a professional plays into the public's general apathy about any fabncare process 
until something goes wrong and then the cleaner is assumed by the customer to have damaged or 
destroyed an article through ignorance or negligence. 

Most often, the manufacturer or designer is sacrosanct and the more expensive the article and the 
more expansive the designer's celebrity, the more invaluable the aura. The fabncare industry lacks the 
economic clout to challenge the operative cliches reinforced by media and standup comics, that the 
cleaner lost my shirt, broke my buttons, ruined my suit and, of course, overcharged, especially women, 
resulting in the classic topper of "being taken to the cleaners." 

Rodney Dangerfield said it best. "We don't get no respect." And the proliferation of the one 
price discount cleaners and the dominance in urban centers of plant ownership by new immigrants with 
limited English communication skills fuel the public impression that cleaning is cookie cutter simple 
rather than art and science practice by true professionals. The fabricare industry seeks respect from 
government and finds itself in expensive opposition to local and state initiatives that threaten industry 
survival. Most importantly, Federal environmental statutes have caught fabricare businesses in a web 


35 


meant for Love Canal level polluters and have saddled drycleaners with an ex post facto law, which many 
believe, as I do, should be ruled unconstitutional. 

Perchloroethylene is the solvent used by about 85 percent of America's drycleaners, all of whom 
live under a sort of Damocles. It is paradoxical that this visionary arm of the Environmental Protection 
Agency, the Design for the Environment, has enlisted fabricare industry cooperation in seeking 
approaches, which could limit the use of petrochemicals, thereby compromising plant owners' lifetime 
investments, while EPA's Enforcement Division has the potential to bankrupt almost all of those 85 
percent who clean with perc. 

Let's look at the psyche of America's average drycleaner. He feels attacked by his government, 
fearful that he may lose both his business and his life savings, concerned that maybe the cancer scare 
stories are true. He is unsure of customer loyalty as one-pnce discounters appear in major neighborhoods. 
He has limited space, limited capital, and really doesn't want to add to his notes or risks by embracing 
wetcleaning. Despite all the technical assistance his trade association, if he is a member, can provide, he 
feels he lacks the ability to communicate effectively with his customers, many of whom don't respect his 
industry or him as an expert in his craft. 

The moms and pops of the nation's fabricare industry are tired, tired from stresses and from 
working 12 hour days, six or seven days a week and, even if they are closed on Sundays, coming in to do 
book work or machinery maintenance. Despite Money magazine's portrayal years ago of drycleaning 
millionaires, most cleaners buy a job and they make no more than a decent living. They have washed 
articles, as necessary, as long as they have been in business, but large-scale wetcleaning as an alternative 
to their perc machines is going to be a hard sell. 

The analysis laboratones of the International Fabricare Institute and the Neighborhood Cleaners 
Association International have archival histones dating back through at least five decades of apparel and 
household articles that did not withstand normally accepted professional care practices. The advent of the 
Federal Trade Commission Care Labeling Rule hasn't stemmed the flow of unserviceable merchandise. 
Although manufacturers are required to assure that no harm will come when care label instructions are 
followed, the analysis labs year after year report fugitive dyes, dimensional distortions, loss of sizings, 
and other disasters, even when care instructions were presumably followed. 

Now, add two new variables: care labels as symbols only, no print instructions—to which, despite 
the potential for confusion, FTC is committed. The FTC is not ready to develop a separate professional 
wetcleaning symbol. So, if the cleaner makes a mistake in judgment, it could be the fabricare 
professional who is hung out to dry. 

These perceived impediments are not presented as a rationale to forget about large-scale 
wetcleaning, but they are posited to continue to use aqueous metaphors to offer the cold water of reality. 
Water may be the universal solvent but it is not accepted at this time by the fabricare industry as the 
universal solution, nor in my opinion should it be. 

Wetcleaning should be viewed as a controllable adjunct to drycleaning, not a replacement. 

Exactly one year ago, my plant entered the mixed use category and I have a moderate success story to 
relate to you. I replaced my 20 year old dry-to-dry perc machine with a petroleum unit using Exxon's 
DF2000 fluid and added two computerized wetcleaning machmes, a computerized dryer, two 
conditioning presses, and a new age wind whip. Fortunately, my cleaning technician is Elaine Harvey, 


36 


former IFI instructor and garment analyst. And I was counseled by Anne Hargrove, who ran Chicago's 
Greener Cleaner, the hundred percent wetcleaning shop. Our experience has been most favorable. We 
wetclean about 30 percent of our customers' articles, based upon their requests or our judgment of the 
appropriateness of the water treatment. 

We have not experienced one single damaged piece. I attribute this record to the excellence of 
the technology, Anne's instructions, Elaine's wisdom, and our finishers' hand skills. We announced the 
new technology last April in a mailer to our regular client base and by display information in our call 
office library. We conduct plant tours and advertise in a holistic health magazine. 

Our service approach has been the subject of an article in The Washington Post Home Section. A 
front office mannequin wears a woolen sweater, woolen sport jacket, and pants, all identified with a 
pinned-on sign saying "I was wetcleaned." Our outdoor signage and all company stationery state, "New 
Cleaning Technologies, Kind to Clothing, Allergies and Ecology." In an adjacent building we have 
established the Prestige Fabricare Education Center offering instruction to groups and individuals in 
selection and care of apparel and household textiles. I chose to switch from perc to petroleum partly to 
avoid the stigma with which perc is now associated, but mostly because the lower KB fluid is more 
appropriate as a cleansing agent for the preponderance of delicates we process. 

I have been extremely vigilant to introduce our petroleum cleaning and wetcleaning in positive 
ways and decry the cancer scare tactics used by some wetcleaners in promoting their services. Although 
my company is fortunate in having people with fabricare knowledge and developed technical and 
communicative skills, we are nevertheless conservative in offering that new technology called 
wetcleaning. In cases where we recognize high risk processing factors, we employ a customer agreement 
form and it is no mere disclaimer. We advise our customers to choose wetcleaning if one or more of 
these criteria exists. I will skip that because it is on the handout if you look at the wetcleaning form there. 

I want to emphasize that the circumstances under which my company offers wetcleaning are far 
from typical. I operate a high end business and have done so for the past 18 years in one of the wealthiest 
counties in America. My customers are nearly all well-educated, intelligent, and aware. As a senior 
citizen, whose children are grown and established, I don't face the economic pressures of the average 
fabricare professional. The fabricare industry awaits the proven viability of the newest processes, Rynex 
and liquid carbon dioxide. Until they have been field tested significantly, water remains the new process, 
which needs to be effectively introduced to the public. 

Given all the impediments to which I have referred, I believe that the average drycleaner in 
America is not in a position to effectively introduce and market wetcleaning. Although the fabric trade 
associations provide abundant technical assistance to membership through illustrated bulletins, classes, 
and field demonstrations, the associations do not have the public's ear. 

Even a public service media campaign by EPA would disappear without an impact for lack of 
context. It is the fashion industry, apparel designers, manufacturers, retailers, the media, and perhaps 
most importantly the mediagenic fashion and entertainment and sports superstars, who can show the way. 

A significant portion of stylish apparel must be truly professionally wetcleanable and are clearly 
not home washing candidates. Only the designers can choose the combinations of dyes, weaves, 
construction, and trims which will be safe to water process. Only the fashion/entertainment confluence 


37 


can offer the excitement which will rivet the public attention vital to a massive effort to redirect public 
dressing and fabricare maintenance habits. 

EPA's Design for the Environment is wise to have courted the upstream components of the textile 
apparel chain to join in a dialogue at this conference. I have a vision that the burden of unfair calamitous 
environmental legislation will be lifted and that the truly remarkable successful efforts of the fabricare 
industry to clean up its own act will be recognized, that the realities of public education will be faced, that 
serviceability and wear and care will be fashion's first concern, and that fabricare will assume a proper 
role as a legitimate partner, not an adversary, of the fashion world. 

To the fulfillment of that vision, I propose a "fashion meets fabricare" summit in New York City, 
initiated and coordinated by EPA's Design for the Environment to further the stated objective of seeking 
an ever cleaner environment. 

Thank you. 


38 


POINT OF VIEW 

ED BOORSTEIN 


Fabricare Professionals...Sustaining Life 


F irst, let’s get the terminology right: we 
are not drycleaners. We’r e, fabricarists; 
fabricare professionals. Throw in furs and 
leathers, and we go beyond care for fabrics 
and textiles. What’s needed is a compre¬ 
hensive term to encompass all of our refur¬ 
bishing services. 

For now. I’ll settle for fabricarists. We 
sustain and prolong the useful attractive 
life of valued clothing and household arti¬ 
cles. We provide cleanliness and crispness 
to contemporary humankind’s visible 
shells. We make possible the ubiquitous 
garment industry and enhance public 
choice of colorful and warmth-providing 
household goods. 

Fabricarists’ services support, for good 
or for ill, the two-worker family which has 
become a vital element of our ever ex¬ 
panding economy. And despite wash and 
wear and easy care and frumpy Fridays 
and soapless “miracle” home washing 
products, I am convinced that so long as 
we fabricarists provide the level of profes¬ 
sionalism of which we are capable, we will 
sustain the life of our industry. 

Okay, there is obvious retail room for 
limited-service, low-priced cleaning facili¬ 


ties, but the industry center, which must 
hold, is characterized by the client-focused 
fabricarist dispensing all the familiar 
virtues of friendliness, courtesy, reliability 
and ethical practices along with technical 
proficiency and the unending devotion to 
quality and service that define the true 
professional in any line of endeavor. 

We fabricarists sustain our lives, the 
lives of our co-workers, clients, the public 
at large and the ecology of the universe, as 
we seek, find, and develop for usage the 
safest and most environmentally respectful 
products and methodologies possible. 
Sure, our awareness was raised by the 
sometimes “friendly fire” of government 
agencies and issue advocacy groups, but 
our industry has responded, has conceived 
technologies undreamed of a few years ago 
and currently awaits the viability of new 
professional fabricare capabilities that are 
visible now on the horizon. 

Eight years ago I contributed to the 
American Drycleaner a personal memoir 
which was printed under my title, “Seek¬ 
ing Serenity at Sixty.” Perhaps, oddly, I’ve 
found my “serenity” in continued demand¬ 
ing, hands-on (and mind-on) absorption in 



The former Prestige Cleaners, Silver Spring, now has its own distinctive identity—and earns it. 


58 


AMERICAN DRYCLEANER, JANUARY 1998 






my company and my industry. I have been 
blessed with reasonably good health, a lov¬ 
ing family and a loyal, caring staff, and I 
am sufficiently financially secure to have 
invested, with serenity, $175,000 in the 
one plant I have retained (in Silver Spring, 
Md.) and recently re-named Prestige... 
Exceptional Fabricare. Prestige’s signage 
and all printed matter contain the descrip¬ 
tor: “New Cleaning Technologies, Kind to 
Clothing, Allergies and Ecology.” 

After 40 years as a perc plant, Prestige, 
since March, 1997, is now exclusively an 
Exxon DF-2000 petroleum facility—offer¬ 
ing, additionally, computer-programmed 
wetcleaning as well as our hand washing 
and bleaching skills. We built new coun¬ 
ters, carpeted the front half of the store, 
removed ancient pitted tile in back, painted 
over the resultant uncovered concrete with 
shimmering gray deck paint and scrubbed 
and painted everything else in the building 
that did not move. Now, I’m proud to 
guide customers on plant tours showing 
our “eat off the floor” cleanliness, which I 
feel is motivation to maintain this state. 

As I explain the new technologies and 



Ruth and Ed Boorstein find extra serenity 
occasionally visiting with their grandchildren 
—in this case, Hannah, in California. 


their benefits, I have found the revitaliza¬ 
tion of my business exhilarating, and my 
enthusiasm, in turn, is inspirational to my 
customers and my staff. It was the right 
life move for me to make and our sales 
growth, although not spectacular, is reas¬ 
suring, as my business has met the new 
note payments with ease. 

The “kind to allergies” statement grew 
from drycleaning and wetcleaning service 
that I have provided personally to Mrs. H., 
a customer whom I first met in 1980, after 
I bought Parkway Custom Drycleaning, a 
high-end petroleum plant in Chevy Chase, 
Md. Parkway is now owned by my son 
Steve (who is doing very well, thank you). 
Mrs. H. is terribly reactive to perfumes and 
fragrances, and we developed a whole list 
of do’s and don’ts to protect her from their 
intrusion. Her requirements inspired me, 
when Prestige became a petroleum/wet¬ 
cleaning facility, to use only fragrance-free 
detergents and conditioners and to seek to 
serve the chemically-sensitive population. 

I even found a fragrance-free liquid hand 
soap that’s used by hospitals, and all of our 
involved staff scrub their hands in “ER” 
fashion before touching articles processed 
for the chemically sensitive. 

Our efforts for the allergic have not yet 
proven to be a panacea and may never be. 
Chemical reactivity is idiosyncratic. With 
each transaction, I learn more safeguards 
to include in our processing protocol. 
Almost all of their articles are wetcleaned 
and finished on dedicated specialized 
presses, because my chemically-sensitive 
clients have informed us that whatever 
residual perc, petroleum or perfume odors 
remain in press pads where drycleaned 
articles are finished, can precipitate their 
allergic responses. The program is not at 
this time a “profit center.” It presents to 
me a frustrating but challenging intellectu¬ 
al exercise, an opportunity to do a social 
good, access to practitioners of conven¬ 
tional and alternative health care, a public 


60 


AMERICAN DRYCLEANER, JANUARY 1998 






relations entree, a chance to involve my 
staff in a noble purpose—and, just maybe, 
it will eventually be profitable. 

I write my own advertisements and 
information pieces, again, for good or ill. 
As a life-long, third generation fabricare 
professional, I would not knowingly depre¬ 
cate industry use of perc and have crafted 
my public statements about our petrole¬ 
um/wetcleaning capabilities in the most 
focused, positive way I can. I love the 
“hand” that petroleum imparts and appre¬ 
ciate its relative safety for delicates. 

Although petroleum is a low toxicity 
solvent, as a petro-chemical it remains a 
target of advocacy groups and numerous 
individual “green” people. These folks do 
seek professional wetcleaners and EPA has 
listed Prestige as such. The designation has 
found its way to the Internet, generating a 
trickle of new customers which I hope will 
grow to a floodtide. 

So much of contemporary life seems 
focused on simplifying and standardizing, 
seeking “no brainers.” I believe that life is 
most fully realized in engaging the mind to 
master complexities. As I contemplate the 
possibility that technological progress rep¬ 
resented by liquid carbon dioxide cleaning 
could be the industry’s future and render 
my investment obsolete before I make the 
last note payment, it does disturb my 
serenity. But I have faith that Prestige’s 
professionalism will sustain its life and I 
look forward to soldiering on for as many 
more years of healthy capability as the 
good Lord gives me. 


Certified Professional Drycleaner. He has served as 
president of the Metropolitan Drycleaners Association 
and as secretary, treasurer and currently membership 
director of the Mid-Atlantic Cleaners and Launderers 
Association. He has chaired IFI’s Quality Assurance 
Peer Group since 1996. He conceived, planned, pro¬ 
moted and chaired a series of dry cleaner-retailer-con¬ 
sumer seminars through the ’80s to help develop com¬ 
munication, cooperation and understanding among all 
the elements of the “textile chain.” In 1988 he wrote 
and helped produce for the Metropolitan Drycleaners 
Association a 10-minute video, “Material Witnesses,” 
illustrating the interrelationships among all of those 
elements. He may be reached at (301) 588-0333. 


Edward B. Boorstein has been an owner-operator of 
drycleaning businesses and plants since 1951, when he 
opened his first business, a drop store, while still in 
college; his first plant opened in 1957. Over the years 
he has had as many as 13 locations, but currently all of 
his focus is on Prestige... Exceptional Fabricare. 

Ed holds a B.S. in marketing and an M.A. in labor 
history/urban studies, both from the University of 
Maryland. In 1956, he also took the three-month 
General Course and Management Course at IFI’s pre¬ 
decessor, the National Institute of Drycleaning, and 
since then has taken assorted specialized classes. 

He is a Certified Environmental Drycleaner and 


62 



For the chemically-sensitive unable to tolerate dry cleaning... 

for the environmentally aware searching for "Greener" solutions... 

PR€STIG€ 

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fl N€UI RITERNRTIVE FRBRICRRC TECHNOLOGY... 

UJ€TCl€ANING 


An environmentally responsible professional fabricare answer for many of those who are severely reactive to petro¬ 
chemicals, fragrances and perfumes and/or committed to the "greener" way. 

Our fragrance-free wetcleaning technology permits us to clean in water without shrinkage up to 70% of clothing and house 
hold articles that are care-labeled "dryclean only". Yes, wools, silks, linens, rayons and cashmeres. Even the most well 
designed home washing machine is unlikely to match the capabilities of our computerized wetcleaning equipment. 
Micro-processors control water temperatures, cylinder speeds, mechanical action and moisture removal. Special condi¬ 
tioners protect the "hand" or feel of a garment's fabric. Our micro tumbler provides 10 levels of sensor monitored dry¬ 
ing and our "tensioning" presses complete the process by aiding the retention of original dimensions. 

We maintain a dedicated "chemically sensitive" area and scrub our hands with a fragrance-free soap in "ER" fashion 
before handling articles belonging to our chemically sensitive clients. 

For the remaining 30% of articles which cannot be wetcleaned safely, we offer drycleaning with a difference; a non-chlori- 
nated, fragrance-free, virtually closed circuit, near odorless, uniquely gentle hydrocarbon process; ideal for the most 
delicately constructed articles. 


Prestige...Exceptional fabricare is listed by €PR and Greenpeace as an accredited wetdeaner. 


Master Cleaning technician; 

35 year industry veteran; 
former technical instructor, 
textile analyst and lecturer at the 
International Fabricare Institute 


Ed Boorsicin Elaine Harvey 



Hands-on owner-operator since 1964; 
45 year industry veteran; contributing 
writer American Drycleaner magazine; 
Certified Environmental Drycleaner; 
Certified Professional Drvcleaner 



Should you wish to discuss our methodology, please call €d or Elaine at 301-588-0333. 


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INRODUCTORV OFFER • INRODUCTORV OFFER • INRODUCTORV OFFER • INRODUCTORV OFFER • INRODUCTORY OFFER 

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drycleaning order and a $5.00 credit will be applied. 

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Offer expires May 31,1998 

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9420 Georgia Avenue, Silver Spring, MD • 20910 • 301-588-0333 

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INRODUCTORY OFFER • INRODUCTORV OFFER • INRODUCTORY OFFER • INRODUCTORV OFFER • INRODUCTORV OFFER 

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PR€STIG€...€XCCPTIONRl FABMCARC 

Ncui Cleaning Technologies Kind to Clothing, Allergies, & ecology 


9420 Georgia Avenue, Silver Spring, MD 209 1 0 301 -588-0333 Fax 301 -588-7914 



















PRESTIGE...EXCEPTIONIH FRRRICRRE 

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9420 Georgia Avenue. Silver Spring. MD 209 1 0 30 1 - 588-03 3 3 Fax 30 1 - 588-79 1 4 



Wetcleaning 

Kind To Clothing 

Professional wetcleaning is an alternative to the time consuming task of home washing and ironing of articles 
care labeled "washable" and for much clothing care labeled "dryclean only". Wetcleaning is often a necessity for 
restoring "dryclean only" items with large amounts of water soluble staining, water "rings" or bleachable 
yellowed or dingy areas. 

Even the most well designed home top loader is unlikely to match the capabilities of our new Unimac VF 18 wet¬ 
cleaning machines. Micro-processors control water temperatures, cylinder speeds, mechanical action and moisture 
removal. Special conditioners protect the "hand" or feel of a garment's fabric. Our Unimac micro tumbler pro¬ 
vides 10 levels of sensor monitored drying and our Veit " tensioning " presses complete the process by aiding the 
retention of original dimensions. 

Kind To Allergies * 

For people with petro-chemical sensitivities, wetcleaning is a viable alternative in maintaining most silks, wools, 
rayons, linens and cottons which are care labeled "dryclean only". All detergents, conditioners and sizings that 
we use have been customized to our specifications to be fragrance-free. Finished articles should retain no odors or 
residues. 

Kind To Ecology 

All of our wash products are non-toxic, chlorine and phosphate free and biodegradable. 



Drycleaning 

Kind To Clothing 

Our new Permac K25 cleaning machine uses DF 2000 hydrocarbon fluid, developed for the drycleaning industry 
by the Exxon Corporation. DF 2000 is an extremely mild solvent ideal for safeguarding soft fabrics, delicate 
constructions, sensitive dyes and fragile trims such as sequins, beads and pearls. The solvent imparts a soft, 
luxurious "hand" or feel to all fabrics. 


The Permac machine is computerized and multi-programmable so that it can be bathtub gentle for fragiles and 
increasingly active as garment durability and state of soiling demand. 


Kind To Allergies* 

DF 2000 fluid is a non-chlorinated. nearly odorless solvent. All detergents, conditioners and sizings which we use 
have been customized to our specifications to be fragrance-free. Permac s drying sensor assures that cleaned arti¬ 
cles are dried thoroughly. No odors or residues should remain. 


Kind To Ecology 

The Permac machine is a combination drycleaning and drying unit; a closed circuit virtually emission free and 
Exxons s DF 2000 solvent is so mild chemically that EPA classifies its filter and distillation residues as non-haz- 
ardous. 


*Please understand that we intend to work closely with chemically-sensitive clients to render irritant-free results, 
but we cannot and do not guarantee at any time that this goal will be achieved. 


' 

New Cleaning Technologies Kind lo Clothing, Allergies, & ecology 












PR€STIG€...€XC€PTIONAl FAARICARC 


9420 Georgia Avenue, Silver Spring, MD 209 1 0 301- 588-033 3 Fax 30 1 - 588-79 1 4 



The New Prestige Fabricare education Center 



Ed Boorstein 



Ruth Boorstein 



Elaine Harvey 


Free Seminars on Clothing Care 

TO: Prestige Customers, Schools, Church and Synagogue Groups, Clubs, Sororities, 
Fraternities... and Interested Individuals 

WHAT'S INCLUDED: Drycleaning plant tour, video on serviceability, explanation and 

discussion of new "pictures only" clothing care labels. Question 
and Answer segment on any aspect of clothing selection, 
professional and home care. 

WHEN: Daytime sessions for students by appointment, 

Wednesday evening sessions for adults from 7:00pm to 9:30 pm 

WHERE: At Prestige...exceptional fabricare 

9420 Georgia Avenue, Silver Spring, Maryland 

WHO'S TEACHING: Elaine Harvey, Prestige staff technician and former International Fabricare 

Institute instructor, textile analyst and national lecturer; 

Ed and Ruth Boorstein, longtime Prestige owners. 

Various guest lecturers 

HOW TO SIGN UP: Just fill out the form below, detach it and either leave it 

with a member of the Prestige staff at the store, or mail it to Prestige at 
the address above. 

QUESTIONS? Please call Ed Boorstein 301-588-0333 


Group Name 
Individual Name 
Address _ 


Contact Person 
Home Phone 
Work Phone 


Date interested in attending: Wednesday,_ 

or Other Choice 



New Cleaning Technologies Kind to Clothing, Allergies, & ecology 



























PR€STIG€...€XC€l>TIONAl FABRICARC 


9420 Georgia Avenue, Silver Spring, MD 209 1 0 30 1 - 588-03 3 3 Fax 30 1 - 588-79 1 

CUSTOMER AGREEMENT FOR WETCLEANING 


Wetcleaning is a care option we offer 

1. In cases where only water processing will assure optimum spot/stain removal of water soluble 
elements such as heavy soil, large areas of beverage spills or body fluids. 

2. To combat yellowing, greying, dulling or dye transfer. 

3. To those who, because of their environmental concerns, choose to avoid a petro-chemical 
cleaning process. 

4. To those whose chemical sensitivities preclude a petro-chemical care method. 

The term "wetcleaning" encompasses all water immersion care methodology from "dipping" in 
cold water, hand washing, bleaching and dye stripping to use of our "new technologies" micro¬ 
processor programmed wetcleaning washers featuring controlled water temperatures, cylinder 
speeds, mechanical action and moisture removal. 

In wetcleaning we use only biodegradable, fragrance-free detergents, softeners and conditioners 
which contain neither chlorine nor phosphates. We choose, as appropriate, one of four gentle 
drying methods; air, warm air blower, warm air cabinet or micro-processor dryer. After 
wetcleaning and drying, we condition garments on our new "tensioning" steam air Finishers to 
relax fibers which may have contracted. 

If an article is care labeled washable, responsible wetcleaning should be virtually risk-free, but 
wetcleaning a drvclean only piece, contrary to manufacturer instructions, does present concerns, 
chief of which are: 

Dimensional change - shrinkage, stretching, distortion 
Change of "hand" or feel; loss of sizing 
Color change (try to wetclean all parts of a matching outfit at the same time) 

We employ our technologically advanced equipment, fabricare knowledge and hand skills to 
wetclean with maximum safety, beginning with making sound judgments in determining suitable 
wetcleaning candidates. We ask that our clients sign below to share the responsibility by 
authorizing the process in full knowledge of the risks involved and agree to hold our company 
"harmless" should change due to the water process be uncorrectable. 


Customer Signature authorizing water process Date 

Chemically sensitive / / yes /_/no 

Measuring required /_/yes /_/no 


Comment 


Ncuj Cleaning Technologies Kind to Clothing, Allergies, & ecology 


















The 100 Percent Wetcleaning Operation 


Debra Davis 
Cleaner by Nature 

Deborah Davis is the founder and owner of Cleaner by Nature, a 100 percent wet¬ 
cleaning operation. Currently, Cleaner By Nature has two stores in Santa Monica and 
West Los Angeles. 


Thank you very much for inviting me to be here today. I must admit that being the only 100 
percent wetcleaner on the agenda, I was a little bit concerned about the kind of reception I might get 
today. So, I can put you all at ease nght now by saying I am not here to tell you to switch to wetcleaning. 
In fact, as a business owner, it is really not in my interest to ask you to switch to wetcleaning. Frankly, I 
kind of like having a lock on that market and I am not looking forward to a lot more competition. 

Now, I do have to tell you that I do believe that a switch to alternatives is inevitable and I am here 
today not so much as a business person but as a consumer and as a concerned citizen telling you that I am 
eager to help other progressive business people who want to switch to these alternatives quicker and 
succeed in the future. But the choice really is yours. 

I will tell you briefly about Cleaner By Nature. As mentioned in the introduction, we are a 100 
percent wetcleaning facility, but more than that, you need to understand that Cleaner By Nature is a 
progressive future-oriented company. We are operating m the future already. We recognized the 
convergence of social trends and technological developments and we got involved in these changes ahead 
of the curve. 

In our two years of operations, we can now say that wetcleaning is no longer a matter of proving 
whether or not it works. Wetcleaning is no longer an emerging alternative, but a proven technology, as 
mentioned by one of the speakers this morning. Furthermore, wetcleaning's success has helped spawn the 
rush to market for some of the other alternatives. The genie is out of the bottle. The alternatives are 
coming. The industry is going to change and Cleaner By Nature, I believe, is on the leading edge of that 
change. 


I am here today to provide my perspective on how the stakeholders in this room can make this 
change happen more quickly and to the maximum benefit of everybody here. Again, having the unusual 
position here of being the only 100 percent facility, I would like to directly address the goals of the 
conference and provide you with my perspective on those goals. 

The first goal was to hear about the latest research on new cleaning technologies. Well, there is 
no better research laboratory than the real world, right? And I can tell you Cleaner By Nature is two 
years old. We are still a small company, but we have grown quickly in that amount of time. We are 
processing approximately 6,000 pounds of garments per month. 

We had a profit margin last year that was comparable with industry standards and we just opened 
our second store last week in West Los Angeles. So, now we have two agencies and a central plant with 
plans to open more. I won't go into that any further. I know that there are others on the program, both 
today and tomorrow, who are going to discuss more specifically results from wetcleaning. 


39 



The other goals of the conference are to talk about exchanging ideas and information toward the 
development of long-term plans for incorporation of pollution prevention practices, to engage the textile 
and apparel industry and regulators in dialogue about what can be done to address these emerging 
alternatives, and wetcleaning in specific. To the regulators I say, first of all, recognize that the industry 
has changed. As I said, the genie is out of the bottle. The change is happening. It is no longer a question 
of if, but when, and how quickly. Why is it changing? First of all, customers are demanding it. 

As we were able to show in our market, and as other wetcleaners are showing in their markets, 
when customers understand the factors involved and that they have an alternative, they want the 
alternative. 

Secondly, entrepreneurs are demanding the alternative. Folks like me and others out there want 
to get involved and push these new technologies. Landlords are demanding it. I haven't heard that issue 
raised yet today. 

But, I say to the drycleaners, even I am having difficulty looking for sites. The first thing a lot of 
the landlords and real estate brokers are telling me is we don't rent to drycleaners. So, that is another push 
factor. And fortunately, the manufacturers are obliging us and stepping forward and creating these 
technologies to meet the demands of the groups that I have mentioned above. 

So, recognize first of all that this is an industry that really has changed. I shouldn't say is 
changing. It has changed. The change is in process. Get on board now. 

The next thing you can do is facilitate the development and acceptance of these alternatives. 

What you are doing today is a wonderful step in that direction. I commend the EPA for holding this 
conference today. You could also help to get information out to the public about the industry and about 
the changes happening. 

Furthermore, enforce current regulations on drycleaners and give incentives to help them change 
to these new technologies. They can add wetcleaning as part of a mixed use facility and eventually 
switch over entirely. Use both the carrot and the stick to make this happen. 

Supporting a network of alternative cleaners would also be very useful to us out there. I think we 
have our own set of needs, having a network or a guild or an organization that would help us speak to 
each other, communicate with each other, improve our services, and improve public education would be 
very helpful in helping facilitate this change. Finally, encourage the textile industry toward certain 
beneficial practices. 

The other group we want to address today is the textile and apparel industry and really, Ed did a 
very good job of summing that up, that you are exactly right. The textile and apparel industry plays a 
very important role in helping the fabricare industry to succeed ultimately. 

Start by making garments that are more friendly to environmentally friendly alternatives. 
Specifically test these garments for compatibility with alternative processes and label them as such. This 
has other benefits for you. First and foremost, it is going to increase customer satisfaction of your 
product. You can start marketing your product not only for its beauty and its style, but also for its 
serviceability. 


40 


Remember that our speaker this morning spoke about value-added being very important in today's 
economy. That is a value added that you can put on your products by saying, not only are they stylish, 
but you don't have to pollute the environment by having them cleaned. It also improves your image and 
reputation as a company that is progressive and environmentally friendly. Finally, the textile and apparel 
industry can also be supportive of a network or guild for environmentally friendly cleaners. 

The last two objectives were to review challenges and barriers to certification to gather proposals 
for voluntary joint stakeholder-led projects. Again, I want to stress this notion of a network and I am 
willing to step forward today and take the lead in organizing such a network if others will help support 
that. 


This network would help provide the education and training that was spoken about by both of the 
previous speakers. We do need good education and good training programs as these alternatives emerge 
and ongoing training and education as new developments come about. 

We also need to educate the public. A network like this would be useful in distributing good 
public information. We need policy support. We need to be aware of what is going on in policy arenas 
and in forums like this and a network would help us get this information out. 

I think that certification also makes a lot of sense. I really believe that in the future it is not going 
to be just wetcleanmg as an alternative, but probably a combination of alternatives. That is going to make 
the whole industry that much more complicated. I think certification would be a very useful tool for 
cleaners and for the consumers. 

In conclusion, I want to say that Cleaner By Nature recognizes what Ed Barlow said this morning, 
that we are not really in the cleaning business. We are in the business of creating and supporting people's 
lifestyles, their lifestyle choices. That is how we see our business. We are already living in the future, 
operating in the future and we welcome anyone else out there who wants to join us. 

Thank you very much. 


41 


A Business Perspective on Wetcleaning 


Ken Adamson 

Canadian Fabricare Association 

Ken Adamson is currently President and sole shareholder of Langley Pansian Limited 
since 1984. He has been particularly active in the fields of occupational health and safety 
and environmental issues. 


Thank you very much, Bill. 

I grew up in the drycleaning business and I had the great fortune of being trained by people with 
the level of experience that Bill has. I also grew up in what we call in the industry a mixed plant 
environment. So, I very much grew up with water and wetcleaning, as well as drycleaning. 

I became involved several years ago on both sides of the border with both EPA and Environment 
Canada in various wetcleaning projects. There were a lot of claims at the time about the feasibility of 
wetcleaning and we were hearing everything from being able to wetclean 100 percent of goods to not 
being able to wetclean anything and clearly neither of those positions was likely true. 

Having grown up in the mixed plant environment, I intuitively thought that a lot of this just 
wasn't a big deal. In that environment there are many factors that determine whether something goes on 
the wet side or dry side and it just isn't the polarized environment that we seem to be encountering. 

So, with that in mind, with the help of Environment Canada and R.R. Street & Company, we 
embarked on a task and experiment of setting up a dedicated wetcleaning plant. By dedicated, I mean that 
only wetcleaning was done on this particular site. We still had access to nonaqueous processing and 
nonaqueous processing should not necessarily be equated with perchloroethylene drycleaning. I think in 
terms of being stuck in paradigms; that is a mistake we often make. Nonetheless, I think as fabncare 
professionals, it is terribly important that we recognize that one of the distinctions that makes us 
professional is that we have access to both aqueous and non-aqueous processes. But we felt for the 
purpose of this experiment, that this particular site had been a drycleanmg plant for about 45 years and 
clearly force of habit would enter into things if there was still dry cleaning equipment on site. 

The purposes of the study—and we worked very closely with Dr. Manfred Wentz on this study— 
were to define the process parameters for aqueous textile cleaning, to develop guidelines for the process, 
and to demonstrate practical boundaries for the process. We very much focused on having the operator in 
the plant select the proper method, that is, Renee would decide whether something would go aqueous or 
nonaqueous and, most important, we decided very early on—and I do not advocate this in anything other 
than a test sort of situation—we gave Renee the authority that if she felt something labeled "dryclean 
only" was wetcleanable, she had permission to do that and we would accept any liability that might result. 

The test period that we recorded ran from the end of September in 1995 to the end of March in 
1996. There were 12,123 pieces recorded in the test period and we kept track of them by garment and 
fiber type. For fiber type, in the case of a blend, it was recorded as the predominant fiber type. Canada is 
a relatively cool climate, cold climate at that time of the year, and the breakdown not remarkable, 6,655 


42 


wood pieces and you can see how it progresses from that point down. Clearly not a great deal of silk and 
linen at that time of year. 

There were just a couple of surprises. For the test period of the wool pieces, we were able to 
wetclean 43 percent. There is one qualifier. This particular site does a lot of work for the local police 
department and there are a lot of very tightly woven gabardine wool pants that wetclean very, very well. 
We haven't yet encountered any policemen in the Hamilton area running around trying to catch their 
breath or looking constricted because their pants are too tight. 

That phenomenon somewhat distorts the wool figure. There are a lot of wool police pants that go 
through, but they wetclean very, very successfully. Fifty-seven percent of those pieces were drycleaned. 
Generally speaking, cotton will wetclean well and that is demonstrated in the 96 percent. 

I am going to skip rayon for a minute. The thermoplastics, the synthetics, 80/20. That is really 
no surprise. If you regard 42 pieces of silk and linen as a valid sample, which it really isn't, 21 were 
wetcleaned, 21 were drycleaned. The rayon is a bit of a conundrum. Anybody with a background in 
textiles in the room, and I see a number of people that have that background, know that rayon has poor 
wet strength; it generally does not perform well in an aqueous environment. 

Renee has had a great deal of success with rayon, however; 67 percent wetclean, 33 percent 
dryclean. I am at somewhat of a loss to explain this from a technical standpoint, other than there is rayon 
and there is rayon. There are many different formulations of rayon. We certainly take great care to resize 
garments after they have been wetcleaned and we really haven't had any particular problem. 

From an overall perspective for the six-month period, we were able to wetclean 61 percent of the 
throughput; 39 percent went off site to be drycleaned. They are only drycleaned off site. They come 
back on to the site for finishing purposes. We also monitored a three month period from the 1st of 
January to the 31st of March in 1996. I reasoned anecdotally—and I tend to do that—that during that 
period of time there would be a proliferation of very heavy wool garments and that the feasible 
percentage of wetcleaning was going to fall. 

I am not very good, but I am consistent, because I was dead wrong. By this time, Renee was 
really getting good at it and she was able to achieve an even higher percentage of wetcleaning. And you 
can see what has happened there. The wool numbers have reversed. With the police pants, initially they 
were being drycleaned. Over the fall period, more and more of them were wetcleaned and to this day 
they are all being wetcleaned. 

The cotton numbers, again, aren't a surprise. The rayon numbers are and I am not going to 
comment on that. The thermoplastics aren't a surprise and there weren't any silk or linen pieces during 
that period of time. 

During the period that we call the endpoint of the cleaning—of the methodology—we were able 
to wetclean 75 percent. We call it the end point because we feel that on this site—and I stress "on this 
site"—that is probably the maximum feasible percentage for economical wetcleaning. 

There are three formulae here that we use. The machine is a Milner. It is a very sophisticated 
machine, an excellent controller. It gives us absolute control over motor RPM, over dwell time, over 
temperature parameters. It controls very, very well. We have a programmable American dryer that 


43 


controls by temperature, by time, and by relative humidity, also a very sophisticated machine. It is steam- 
heated. 


But there is really nothing magic. Anyone that grew up in the laundry business knows that these 
really aren't very exciting formulae, other than we have some dwell time between the reversals in the 
machine and relatively slow RPM. 

I was most interested in my friend, Josef Kurz's numbers this morning in terms of sophisticated 
detergency. We have heard claims about detergents that coat wool fibers to prevent matting and felting. I 
really don't think there is anything tembly exciting about the chemistry we use. It is good basic laundry 
wetcleanmg chemistry and has worked very, very well for us. 

This is a formula for heavier, dirtier garments and really nothing terribly exciting. We have 
extensive cost data on this site going back many years. During the current period, the second line from 
the bottom, we processed 12,123 pieces. In the pnor period, the corresponding period of time the year 
before, sixth month period, we processed 13,439 pieces. Now, somebody might say the market caught on 
to the fact you were wetcleaning and reacted negatively. However, Hamilton was a very poor competitive 
environment at that point in time and the governing factor in the reduction in piece count was that we had 
a 50 percent discount competitor open up a couple of blocks away. And for a short period of time, that 
affected the numbers. You will see in a minute that they have rebounded nicely. 

During the test period, we took all plant processing wages, which exclude counter wages. 

Whether you wetclean or dryclean, you still have to have someone serving the customers. We added a 
plug of $1,350, which accounts for wages in our main facility, where any drycleaning that comes out is 
drycleaned and we arrive at a total processing cost of $13,372 or a wage cost per piece of $1.10. You can 
see in the pnor penod, where everything was essentially drycleaned, other than minimal amounts of 
wetcleaning, we had wage costs of $1.07, relatively insignificant differences attnbutable mainly to the 
drop in piece count, as opposed to any change in process. 

We hypothesized that, as long as we focus on garments that are wetcleanable and fmishable, there 
really is very little difference in finishing costs. Generally, in this site we drew the line at men's tailored 
garments. As soon as we strayed into the realm of men's tailored garments, then costs very much spiked. 
But, again, keep in mind this plant is in a lower middle class area. The demographics of the area largely 
dictate that we are just not going to get a lot of tailored clothing. There are many, many pieces going 
through this site that perform very, very well in wetcleanmg. 

In fact, in this site, the numbers pretty consistently run between 60 and 70 percent. I should also 
emphasize that the threshold level vanes drastically for a number of reasons. We have other sites in the 
city of Hamilton where that number would, in fact, be lower and I think our friend, Mr. Kurz, this 
morning presented some numbers that in Germany indicate that between 40 and 50 percent seems to be a 
feasible number for wet processing. And I think I would probably concur with that. 

If we monitor utility costs in the current period, or the test penod—the boiler was oil-fired—we 
amve at a cost per piece of 15.07 cents for fuel compared to 12.03 cents in the immediately preceding 
year and that is not a surprise. It takes more energy to evaporate a gallon of water than a gallon of 
perchloroethylene. But, again, it is not an earth shattenng difference and we recovered a lot of that cost in 
the area of electricity because in the prior period, we were using a fairly old inefficient electric water 


44 


heater to do what little wet processing we did. We replaced that with a natural gas unit and—even adding 
back the natural gas—we picked up a reasonable amount of the difference. 

I think that demonstrates that you can plan with those numbers and arrive at a reasonably 
workable situation. Water consumption was an interesting phenomenon. Water is generally not 
recirculated in Canada for two reasons, probably neither of them terribly valid. There is a lot of water in 
Canada, so it is not perceived as a terribly precious commodity. That is unfortunate, but that is the 
perception. Secondly, because of the cold climate, water towers can freeze and we tend not to recirculate 
water. The drycleaning equipment that was in this plant was second generation. It was quite efficient in 
terms of the mileage we were getting but, nonetheless, it was water-cooled. 

One would reason that you would use a lot more water wetcleaning than drycleaning. But this is 
not so, if you happen to be using equipment prior to third generation. That equipment uses a lot of water 
for cooling if it is not being recycled. And as you can see in actual fact, our costs were lower for water in 
wetcleaning than in drycleanmg. 

Now, I have to stress in presenting these numbers that when we get beyond second generation in 
the third, fourth, and fifth generation, those machines make fairly sparing use of water and they would 
win hands down in this scenario, but you have to be a little bit careful of making a blanket statement that 
wetcleaning uses more water than drycleaning. It certainly wasn't true in this case. 

I think that we can draw several conclusions from the study and I have one overhead slide, after I 
go through these conclusions. Clearly, in my mind, a substantial number of garments that we previously 
drycleaned can, in fact, be wetcleaned using either new or really traditional wetcleaning technology. The 
one thing I think that newer wetcleaning technology brings to the party compared to traditional 
methodologies is process control. Whatever one might say about modem drycleaning, there is a great 
deal of process control embodied in the equipment, the solvents, the chemistry. Traditional wetcleanmg 
is mired in the 1930s time warp. There is not a lot of work done on it. With newer technologies, we start 
to impart some degree of process control and instead of having six sinks and a corresponding number of 
people working on wetcleaning, we can start to replace human input with mechanical input and impart 
some degree of process control. 

From an overall perspective, however, I think I have to say that a lot of the process control, even 
with machine-based wetcleanmg, is based in the operator's head as opposed to in the machinery. It is 
going to be interesting to see how that develops over the next number of years. 

I think from our standpoint, in our area and on this site, we certainly still need access to both 
aqueous and nonaqueous technologies. That doesn't mean that you have to have them on every site, I 
think we proved that. I think we also established that there are a number of factors that determine what a 
feasible percentage is. One that is often ignored—as a matter of fact, I never see anything on it in the 
literature—is the phenomenon of lot control. This is a thousand or fewer pieces. This site would process 
32 or 33 thousand pieces a year. So, the weekly piece count is small, well under a thousand. 

Lot control isn't an issue. If you get up into the two and three thousand piece range, lot control 
becomes immensely important. Wetcleaning doesn't deliver pieces down the finishing line consistently in 
lots. Some clothing is dried immediately. Some has to hang for a little while. Some has to hang 
overnight. 


45 


That variability presents a big problem in a high production site, where lot control is an issue. It 
is really not a big issue in a small piece count site. Is wetcleaning the answer to some of our problems? 
No, it is not the answer. Is it one answer? Yes, very much so. 

Our friend, Dr. Manfred Wentz, this morning, alluded to the textile care spectra. I think as an 
industry we have to stop focusing on whether I should be doing 100 percent or 90 percent or 80 percent or 
75 percent and get back to the basics in terms of focusing on the goods we are working on and basic 
textile parameters. I think we will find that wetcleaning is one of the feasible answers for dealing with 
our problems. 

As a matter of interest, I have some subsequent performance figures for this site. Just to allay any 
fears that there has been a drastic drop in piece count on this site, we can see the numbers of pieces 
processed in the test period, that six month window, is 12,123. That corresponded to 71,889 Canadian 
dollars in sales. 

If we take the two subsequent periods in 1996-1997 and 1997-1998, we can see that the piece 
count is fairly steadily increased along with the dollar sales figures. So, certainly, I think if we look at 
North America as a whole, this may be the longest running wetcleaning site, or it is certainly in the top 
few, and there has been no negative trend there. 

As Buster or Ed said, we have not yet paid a claim on a wetcleaned garment. We tend not to have 
a lot of claims on this site. I think probably in the last three years we paid a half a dozen. They have all 
been on drycleaned items, generally items that were received on a Saturday for sudden service. They go 
off site. They get drycleaned, probably not with a great deal of care and we tend to pay claims. So, I 
don't think the no claims thing is a commentary on the relative efficacy of wetcleaning versus 
drycleaning. I think it is a commentary on the fact that if you carefully select processes for each piece 
going through the plant and carry them out, you are probably not going to pay a lot of claims and I think 
that is the message in the no claims experience. 

I hope I have managed to shed light on our wetcleaning experience and it certainly from my 
perspective is going to be very much part of our corporate equation in dealing with some of the challenges 
that are now presenting themselves and will present themselves in the next few years. 


46 


Korean Cleaners’ Concerns 


Max Oh 

Federation of Korean Drycleaners Association of Greater Washington 

Max Oh has been an advisor for the Federal of Korean Drycleaners Associations for 
many years. He is currently a columnist for the Korean Drycleaners Times, as well as a 
national speaker for the Federation of Korean Drycleaners Associations. 


Good evening, ladies and gentlemen. My name is Max Oh. I want to make a speech only for a 
few minutes, I mean less than ten minutes. 

The subject of my presentation is the coach program, which is being conducted by the Korean 
Drycleaners Association of Greater Washington. As an activity under the EPA's mantle program, the 
objective of the coach program is to educate the Korean businessman about the EPA rules and regulations 
so that they totally absorb and implement the drycleaning practices that are environmentally friendly. 

The emphasis is on education rather than administration of government rules and, as such, the 
coach program is geared to the cooperation between our association members, mutual support, and self 
help. The Korean Drycleaners Association of Greater Washington conducts two or three technical 
seminars each year as a service to its members. In October 1996, we had a seminar on the environmental 
issues where EPA staff was invited to speak. To everyone's surprise, close to 800 businessmen attended 
the seminar. The success of this seminar showed the importance and high interest our members have 
regarding environmental issues and gave us the confidence that we are doing the right thing. 

Through several meetings with the EPA officials, we developed a plan to train the directors of the 
association as coaches. Mr. James Kinney of EPA Region 3 served as an instructor to train about 35 
directors, who have been made to volunteer and the federal EPA issued a certificate to those of us who 
completed the training. When you have a chance, visit the EPA Web site to find out more about it. 

The coach program works in this way. A certified coach makes a visit to a drycleaning store, 
sometimes with advanced notice and sometimes without notice, and inspects the store using the checklist 
of about 87 items, such as store air quality, chemical lists, preventable instruction and measures in place, 
and a record in the file. 

To increase its effectiveness, the coach sometimes invites area businessmen to a mini seminar in 
the selected store and has them observe the inspection. When a deficiency or discrepancy is found, the 
coach discusses it with the store owner, suggests ways to make improvements, and gives two weeks time 
to correct them. After two weeks, the coach conducts a followup inspection and EPA issues a certificate 
when the store passes the inspection. 

It is a simple program but has many advantages. First, for the last 18 months, we educated the 
coach's to the importance of EPA regulations and helped them adopt environmentally-friendly practices. 
Second, it allowed the coaches to pass on what they learned to their fellow businessmen in informal and 
open forums. The goal was not to punish any violation, but to check any discrepancies and to provide a 
chance to correct them. Third, it increased the participation of Korean businessmen in the discussion of 
the environmental issues. As you may know, many Koreans, including myself, are not fluent in English 


47 


and this makes them shy away from asking questions or presenting their own concerns forcefully. But 
with a coach who speaks Korean, they can be as loud as they wish. 

You may ask what about disadvantages and you are right to raise that question. As in any 
program, there is room for abuse. A coach may want to use the chance to inspect someone else's store to 
take out his personal grudges or to give personal favors. We thought about that possibility and 
established an environmental committee of nine members in the association. This committee, of which I 
am the chairman, receives the preliminary results of inspection from the coaches, checks them for 
validity, and serves as a mediator if there is any difference of opinion between the coach and the store 
owner. 


The committee also schedules meetings to review the overall coach program and to issue periodic 
warnings to not accept even a cup of coffee or a soft dnnk in order to maintain your integrity as an 
inspector. The effectiveness of the coach program is approved by the EPA at Region 3. Last year, James 
Kinney carried out his own inspection of the stores randomly selected from the least level store that had 
been the inspected through the coach program. He reported that 100 percent of these store are in 
excellent shape. Already the coach program is spreading due to its success. Upon request from the EPA 
Region 3, the committee members and I carried out our training program for 12 more drycleaning 
association directors and they were certified as a coach by Dr. Montague on March 15, 1998. They are 
ready to go out and educate their members through informal inspection and training. 

Next time, I am going to spread this program to the Philadelphia area, EPA Region 3. Dr. 
Montague asked me verbally but not officially. 

Now, I would like to make two recommendations to the EPA. First, allocate this internal budget 
for the support of the coach program nationwide and for the translation mto Korean of EPA rules, 
regulations, best practices, et cetera. Unofficial estimates of Korean businessmen engaged in the 
drycleaning business in America is about 15,000. Their understanding and compliance with 
environmental requirements would increase greatly if the material were in Korean and the message was 
delivered in Korean through the coach program. 

Second, find a way to provide a low interest loan to the drycleaners. Environmental rules and 
regulations change and regulations require the installation of new equipment and improvement of stores. 
Most of the Korean drycleaners are run by mom and pop, who work 60, 70 hours a week to make a living. 
They do not have any capital to invest and have very little access to the local banks for the investment 
loans. EPA financial assistance would greatly encourage them to upgrade their facility to the EPA 
standard. I hope EPA finds my recommendations worthwhile. 

Thank you again for the opportunity. 


48 


The Fabricare Industry and Change 


Vic Vandermolen 
Canadian Fabricare Association 

Vic Vandermolen has been active in the association management field for the past 
25 years. He became Executive Director of the Ontario Fabricare Association in 1991, 
and is the founding Executive Director of the Canadian Fabncare Association, where he 
continues to serve. 


Good morning, ladies and gentlemen. Thank you for the opportunity to share with you what has 
been happening in the fabricare industry in Canada. To say that we are experiencing change would be to 
put it mildly. I hope to share with you this morning some of the things that are happening, some of the 
comments about why they are happening, and the role of the Canadian association and some of the 
provincial associations in being a proactive part in dealing with the changes and directing those changes 
that are affecting the industry. 

Let me say first of all that neither the board of directors nor the reasonable leadership in Canada 
has ever had any real aversion to change, never viewed the idea of change with any real horror. The focus 
of recognition for change has addressed two specific areas: the need for pollution prevention with 
existing technology and the need for development of alternative technologies. Yes, there remains some 
skepticism that even real change will not provide any real benefit to the industry as a whole, but I daresay 
that the vast majority of cleaners in Canada look on change as an opportunity for bringing new life to the 
future. 


Let me go back just a few years. In December of 1992, the Federal government published the 
environmental code of practice for the reduction of solvent emissions from drycleaning facilities. It is 
important to note that the development of the code was at the initiative of the industry because of 
industry's recognition of the need for change and to codify that change and its ability to convince 
government that this was needed. 

The purpose of the code was to provide guidance to the environmental regulatory agencies and 
the owners of drycleaning facilities regarding the means to reduce chemical emissions from drycleaning 
plants. It was because of a shared recognition that a change was needed, both in the way that regulatory 
agencies responded to this issue and in the way that cleaners dealt with it, that the code was published. I 
say that to further emphasize the fact that the code was developed in a spirit of cooperation and of 
consultation. 

There were 53 people on this task force; eighteen had direct links to the fabricare industry and 
allied business interests were represented. There were also five representatives of the environmental 
community and the balance was people involved in both federal and provincial environmental 
government agencies. I point that out because the attitudes that were developed during the work of this 
task force were used as guidelines for subsequent issues that have led us to the current situation—that is, 
cooperation and consensus building among industry and government and environmental groups when we 
deal with issues relative to the fabricare industry. 


49 


When the federal government was running its election platform the first time—they have now 
been in power for some seven years, it promised that it would take a tough stance on issues affecting the 
environment. Very soon after its election, it developed a priority substances list of the chemicals that are 
governed under the Canadian Environmental Protection Act and classified each into either a track one or a 
track two category. 

Track one chemicals were designated and slated for total elimination. Track two chemicals were 
designated for a cradle-to-grave management policy, and perc was classified as a track two chemical. 

Subsequently, the government established issue tables or discussion groups to deal with each 
track two chemical and proceeded to work toward establishing a set of rules and regulations regarding the 
management of each of those. This included perc, of course. Based again on the spirit of cooperation 
established during the code of practice, government again invited industry representatives to play a key 
role in this process. 

Let me give you a quick overview. There were 27 members of the actual discussion group; of 
those, 16 were directly related to the fabricare industry, meaning that they were either cleaners or in allied 
trades. Two were members of the environmental community and the balance represented various 
government agencies. 

The issue table first met in October 1994 and met some six times between then and the time that 
its report was published in February of 1996. I'm not going to give you a whole report. Just let me give 
you a quick overview and executive summary, if you will, of the key recommendations. 

Number one, all first and second generation drycleaning equipment would be eliminated from use 
by regulation by a certain date. All new perc machines installed after the promulgation of the regulation 
would be required to have a manufacturer’s rating of some 1,400 pounds per gallon. The distributors of 
perc would be held responsible for the collection of perc-contaminated waste; that also addressed the 
issue of groundwater contamination and concern that waste be disposed of in a timely fashion to a proper 
and legal depot. 

Just by way of interest, last week I learned that, as a result of an inspection, one commercial 
cleaner was found to have some 60 barrels of hazardous waste stored in his basement. I guess he was 
looking for a volume discount from his waste hauler. 

The fourth point was that a levy would be placed on the sale of every bit of perc sold to the 
drycleaning sector, with the proceeds to be used for a national operator training and certification program, 
a national inspection program, and a compliance monitoring program. 

Then lastly, it was recommended that all cleaners complete a training and certification program in 
the proper handling of perc, equipment operation, and maintenance practices, by a committee to be 
established. 

The report and its recommendations received the support of the industry leadership as well as 
government. I just want to note that the environmental community did not accept and support all of the 
core recommendations, because it favored restriction on the quantity of perc being used, with an eventual 
goal of elimination of perc as a solvent in the industry. That approach was rejected by government for 
two reasons. First, it is inconsistent with existing international agreements, including NAFTA. Secondly, 


50 


there is confidence within the Canadian government that current technology can reduce perc consumption 
effectively within the cleaning industry. 

Since the report was filed, there have been some changes made, all initiated by government, 
because of the various government jurisdictions being restricted in what they can do under federal and 
provincial mandates. We were made aware of those, and we have been involved in discussions with those 
and have agreed as an industry to support the current position being take by the federal government. 

The current status can be summed up as follows: the essence of the report will probably be in 
place by September 1 of this year, with full implementation of all recommendations by the spring or early 
summer of 1999. That is the time line that was given to us by government representatives also at the 
recent conference in Toronto, hosted by the Canadian Fabricare Association with substantial financial 
sponsorship from Environment Canada. 

Just by way of interest, the purpose of that conference was to look at how the industry in Canada 
can in a practical manner achieve the goals that were set in the strategic options report on perc that I 
referred to earlier. Let me add that the association Environment Canada previously sponsored a 
conference to consider the latest developments in both aqueous and nonaqueous technology. As a result 
of that conference, the association has been able to present seminars right across the country, giving 
cleaners an opportunity to obtain a better understanding of the need for change and for alternative 
technologies and processes. For lack of a better term, this road show, if you will, has also resulted in a 
positive interest in creating a number of dedicated wetcleaning sites in various provinces across the 
country. 


I referred earlier to a new regulation that we can expect later this year. As I said, because of 
provincial and federal jurisdictional mandates, it will deal only with areas that do not impinge in any way 
on provincial jurisdictions. So what will it deal with? It looks like it will deal with elimination of all first 
and second generation equipment. I anticipate that will be by the end of 1999, perhaps a bit sooner, but 
probably that will be the latest date. By December 31, 1999, it is anticipated that it will be illegal for any 
cleaner to operate a cleaning plant using either a first or a second generation machine. 

Perc will be eliminated as a component of any spotting agent. There will be an elimination of any 
self service drycleaning machines using perc. We don't have any in use right now, but the government is 
anticipating that might happen, so they are saying right up front, that will not be allowed. 

All perc will need to be delivered strictly through a closed loop system. The suppliers of perc 
will be required to assume responsibility for their waste management and waste collection, either through 
their own resources or through contracts with other individuals or other companies. And suppliers will be 
required to maintain records concerning perc consumption, the amount and type of waste generated, and 
to what legal facility it was disposed. 

The industry leadership has met with government to discuss these issues. It believes that 
implementation of these requirements will indeed create the level playing field that is absolutely 
necessary if there is to be good order in the industry, equality of regulation, and implementation of some 
minimum standard of competence and knowledge. 

I believe that one of the reasons why the Canadian Fabricare Association has undertaken to work 
closely with government and environmental groups is because I believe that CFA recognizes that the 


51 


fabricare industry in North America as a whole is indeed suffering an identity crisis. In some cases it is in 
a state of disarray, confusion, and decline. The association leadership believes that, with a conscious 
effort to proactively obtain results through consensus, those results will reflect an agreement that can in 
fact then be supported by all. 

From my perspective as an association manager, and Sylvia referred to that, as an association 
manager for 25 years, let me be nght up front. For those of you who know me, and for those of you who 
don't, let me tell you, I have never been a member of the drycleaning industry. I've never operated a 
plant, don't ask me how to run a spotting board or a cleaning machine; I don't know how. So I come at it 
from a totally objective standpoint, I hope. 

But from my perspective, a major reason for the woes and the ills of the industry at large today 
has been its resistance to change and its seemingly dogged determination to promote this concept of 
universality. Much of the industry focus today is on the environment, and that is indeed an important part 
of the industry. It is important for us to agree that there is a need to be environmentally responsible in 
whatever process we use, and that we do whatever we can to minimize the potential negative effect of that 
process. 


In dealing with those issues, I believe the time has come when we as an industry generally need 
to publicly acknowledge that the concerns about the use of chemicals in the cleaning industry and their 
impact on the environment, that these are not pronouncements of a bunch of radicals, but that there is a 
need for us as an industry to address those concerns proactively. We need to act now in the development 
of viable processes that will allow us to continue to effectively reduce the use of chemicals that may have 
a negative impact on the environment m which we all live. 

The major part of the industry discussions today deal with perc. The issue table discussions that I 
referred to earlier dealt with the management of perc. A great deal of those discussions referred to and 
dealt with the issue of setting goals. The issue table members and the Canadian Fabricare Association 
board of directors discussed the matter of industry goals with government arrived at what is believed to be 
a set of realistic and achievable goals in the reduction of perc consumption in the fabricare industry. 

In 1996, in Canada we used some 4.5 kilotons of perc in the drycleanmg industry. The goal is to 
reduce that to 1.6 kiloton by the end of the year 2000. That is the goal that has been established by both 
government and industry, somewhat of a 60 percent reduction. Now, please understand that what is 
anticipated is that at least half of that goal will be achieved immediately upon the elimination of first and 
second generation equipment. The balance will be achieved through ongoing education and training. 

All that of course is going to result in a major change in the industry in Canada. For those who 
have remained current with technologies and developments, I believe the idea of change is looked upon as 
a grand opportunity to restructure their business, to implement new processes and marketing strategies, 
and to also improve the impact their business has had on the communities that they serve. For those who 
take the attitude that, I've done it this way for 30 years and why should I change now, I believe the future 
of the industry is going to be bleak indeed, because they will be unable to deal with the new 
developments, the new directions and the new regulations that will come into the industry, regardless of 
how much we try to resist it. 

In fact, those people would only fit into the third category of people who have to deal with 
change. Ed Barlow referred to that yesterday morning. He said we all have to deal with change in our 


52 







lives, and there are three categories of people. There are those who make change happen, those who 
watch change happen, and those who wonder what happened. I believe that those who wonder today 
what has happened will not be part of the industry tomorrow, because change within our industry is 
inevitable, and managing that change in a positive way should be the goal of our industry leadership and 
association and members. Determinedly fighting it, I believe will only result in frustration and chaos. 

This is just a personal opinion. Neither the environmentalists nor government are industry 
enemies to be fought by the industry as a whole, nor is the cleaning industry a target to be shot at by the 
environmentalists or the government at every opportunity. I believe it is necessary for each to develop a 
recognition that each party has its own set of goals, and to sit down and to reconcile their individual 
objectives. I believe that goal is far closer when there is cooperation than when there is dissension and 
discord. That, I believe, from the Canadian perspective is what we have been able to accomplish. 

The fact that industry leadership meets regularly with government, be it at meetings or at 
conferences or over lunch or coffee, has allowed each to develop an appreciation for the position of the 
other, and has allowed an objective consideration of the issues. 

I sometimes wonder if, because of all the discussion and issues, we haven't lost the ability to be 
objective, regardless of what side of the issue we're on. We sometimes seem to have been so ingrained in 
our own opinions, that we have lost the ability to listen to someone else. When we start to take the 
attitude that universality is our goal, then we have lost the ability to be objective. When we take the 
position that we should be focusing on establishing a universal processor or universal solvent, then we are 
no longer objective. I think that is a goal that is just as achievable as trying to develop a universal 
garment that everybody would wear. 

Consider the situation where a cleaner is located in an area where water is in short supply. Is it 
then still en vironmentally sound to promote wetcleaning as the only means to clean clothes? Is it just 
possible that sometimes, drycleaning is more responsible environmentally, that sometimes the use of a 
solvent-based technology is in fact more environmentally responsible than the use of water? 

I think it is important that we remember that we just can't bury our heads in the sand, nor can we 
throw out existing processes and arbitrarily declare them hazardous, because we need to evaluate our 
current practices with a very objective mind, based on objective standards. 

Whatever our involvement within the industry, each of us needs to stand back and reconsider our 
position and approach it from an objective perspective, looking at all the facts and all the issues. Ladies 
and gentlemen, I believe if we do not do that, then the result is meaningless rhetoric. 

Just very briefly, let me tell you what is happening with the province of Ontario with regard to 
developments and new regulations. The Canadian Fabricare Association has encouraged each province to 
work with its provincial government to establish a set of regulations dealing with education and training. 
That is in the process. The governments of British Columbia, Alberta, Quebec and Ontario have received 
those recommendations, and those recommendations are generally consistent in their intent and content. 

Just recently, I met with the Minister of the Environment and had lunch last week, Tuesday, with 
his Parliamentary Secretary and assistant. Yesterday, I received a call from the office of the Minister of 
Environment stating that they want to have a meeting with us in a couple of weeks, with the specific 


53 








purpose of determining how we can implement the recommendations that have been made by the Ontario 
Association vis-a-vis the fabric registry in that province. 

Let me just tell you very quickly what those recommendations include. First of all, there will be 
created a drycleaners council in the province of Ontario, to which all drycleaners will be required to 
belong. The council would be governed by a board of directors of nine persons, seven of whom would be 
drycleaners, one a consumer representative, one would be a government representative. 

The council would be held responsible for the setting of competency in all standards for Ontario 
cleaners, and it would work with government in the monitoring of industry members to determine 
compliance with the regulations. The authority of the board would come from regulations that would be 
passed by government. 

I know that the board of directors of the Ontario Association and the leadership in the Ontario 
industry generally are looking forward to the implementation of those types of goals, because there is in 
fact a specific goal, and a path has been established to achieve those goals. It is a fact that, unless you 
know where you're going, you never know when you have arrived. 

The important thing is that in the fabric industry in Canada, goals have been set. They have been 
determined through mutual cooperation and discussion. They have been accepted as being achievable by 
the parties involved in the process. I believe all of that allows the Canadian association to be very proud 
of the conclusions that have been reached, the goals that have been set, and the ability to point to the 
benefits of an orderly transition. 

In summary, let me suggest to you that what is being created in the Canadian fabricare industry is 
a business environment where number one, there are clear and achievable goals, number two, the rules are 
clearly established, number three, the application of those rules will be consistently applied to the industry 
as a whole, and number four, there is a uniform standard of competence and knowledge required of every 
professional cleaner. All of that allows the creation of a level playing field that is so necessary for the 
positive growth and development of the industry as a whole. 

I believe all of this does much to eliminate the confusion and disagreement, and allows for the 
realization of a consistency that helps industry members in the development of their own businesses. I 
believe very much that if the Canadian cleaning industry continues to investigate how it can make things 
better, and if it continues to do that in the spirit of cooperation with all interested parties, then we can 
indeed look forward to an exciting future. If we ever decide that we are no longer willing to evaluate the 
old or to search for the new, then I predict that we will be the instruments of our own demise. 

Thanks very much for your attention. 


54 



Indiana's 5-Star Environmental Recognition Program for Drycleaners 

Dave Wintz 

Indiana Department of Environmental Management 

Dave Wintz is currently an Environmental Manager with the Compliance and Technical 
Assistance Program of the Indiana Department of Environmental Management. He 
provides confidential compliance assistance on all environmental rules and also manages 
the Indiana 5-Star Environmental Recognition Program for Drycleaners. 


I'm going to talk about Indiana's five-star program. We were the first to develop such a program 
in the country. We started in the summer of 1995, working with the Indiana Drycleaning and Laundry 
Association (IDLA). It would not be an overstatement to say it wouldn't have happened without strong 
IDLA support. I don't think government could have done it alone. I don't think EDLA could have done it 
alone. But it is truly a partnership, and it has worked to the industry and to the state's advantage in a lot of 
ways. 

First, let me tell you what the five-star program is not. It is not a certification program. Being 
part of the five-star program does not preclude an inspection. It is not an amnesty program. It does not 
reduce your risk of being referred to enforcement from our agency. But it is a recognition program, and 
we do say that we recognize the cleaners who are pledging and doing more for the environment. I did 
want to make that clear. In the first draft of the report that came out of the January meeting that was held 
here, the EPA meeting, it did say it was a certification program, so we need to get that changed. 

A little background on myself. I work for an office in the Indiana Department of Environmental 
Management that provides confidential assistance for small businesses. We are called the Compliance 
and Technical Assistance Program, and we do provide confidential assistance. We are in a separate 
building from the inspectors and the enforcement people. I think part of what interested the association 
was that we do provide confidential help. I think it was all part of the picture. No one particular aspect 
initiated the process and made it all work, but a lot of pieces came together. 

Obviously, you all know about the drycleaner NESHAP. I would consider the five-star program 
and our integrated education effort as being largely driven by the NESHAP, quite honestly. We're a big 
agency, we do pretty well with steel mills and industries that have environmental staffs and that are on a 
regular inspection schedule, but how do we deal with small businesses? We weren't particularly adept at 
dealing with 450 small businesses throughout the state. 

So we took an integrated education approach, worked with the association, and gave them a grant 
to hire a contractor write a simple, easy-to-read manual. All the drycleaners have that available to them at 
a nominal fee - about $25. The association doesn't make any money on it. It just covers mailing and 
copying costs. 

It is hard to ask cleaners to go above and beyond the rules if you don't tell them what the rules 
are. Initially, we developed the manual and concurrently with that developed the criteria for each star in 
the program. 






55 










The review committee was also formed at that time. It is made up of drycleaners, state personnel, 
health department, and solid waste district personnel. That is just to give them a rounded approach. We 
do review each five-star application on its merits. One through four stars is "we trust you," but the fifth 
star is the best of the best, and they need to be reviewed by the committee. 

I'd like at this point to go through the new application. It does become effective in September of 
this year. The program is about two and a half years old, and it is time to raise the bar a bit. I do want to 
point out a couple of things. Why would cleaners want to join the program, number one? Well, you can 
use the program to market your environmental responsibility to your customers. 

In the beginning, the association was a little hesitant for IDEM to publish information and put it 
on the World Wide Web. I think now, because the relationship has matured, they are much more open 
to the mailer that we did, the green mailer. We did a mass mailer to interested parties across the state. 

From the state perspective, we can't endorse a particular cleaner, but we can distribute 
information indicating who we have recognized. It is a fine line, I agree. However, it is in the statute, so 
we can't do much about that. 

We are transitioning into a new era where the state is going to be doing more pushing of the five- 
star program. In the second to last paragraph, we now visit four and five-star applications. We were 
finding situations where—and there are probably still some—some three- and four-star cleaners shouldn't 
have stars, quite honestly. They have compliance problems. For instance, a five-star applicant did not 
know what the hazard communication standard even was. It didn't have a Haz Comm plan. You can't 
even get one star without basic compliance. 

In the new application, we now require that four and five-star applications will receive a visit 
from CTAP, which is usually me. It is not an inspection; it is still under the guise of CTAP, but it is 
much more comprehensive than an inspection that they would receive from the air program, for instance, 
because the air program doesn't care about the Haz Comm plan, doesn't care about hazardous wastes, 
other than keeping it in covered containers. 

Therefore, it is more comprehensive. We look at OSHA, we look at fire marshal requirements, 
and so forth. We're telling them that CTAP looks at more than just environmental issues during our site 
visits. It is a more comprehensive visit. We want to recognize only the best cleaners in Indiana. 

The second page is straightforward, I won't go through that. Name and address, fax number, and 
so forth. One star indicates striving to reduce the use of solvent. It is pretty weak, I know. Respond 
openly and honestly to customers within a reasonable time frame, and then even if they are CESQGs, they 
have to use a hauler. I know most cleaners are doing that anyway, but we just put it in as a baseline 
standard. 

We are setting up a tiered approach. You will notice, you go from one to two to three. The two 
stars have to qualify as a one. This year we are asking them to take hangers and bags, before it was just 
bags. Most cleaners take the hangers back. 

The brochures—in the past we've had these two green and blue brochures. We are unifying these 
two brochures into one, and we're going to call it Garment Care: Where are We and Where are We 


56 


Going? That could have been the title of this conference, too. That is going to go into different solvents, 
different methodologies, and it is going to be a much more comprehensive brochure. 

Then we are asking the two-star cleaners to do Haz Comm every year, even though the rules 
require you to do it only when an employee starts or when you introduce a new chemical into the 
workplace. We are asking for a copy of the Haz Comm plan to be submitted to us, and we will probably 
include the signature sheet that the employees sign. The purpose of that is to keep people honest, quite 
honestly. As I said, we are finding some people who were in the star program and didn't even know what 
Haz Comm was. 

On the three stars, I don't think much has changed regarding the old criteria. We are requiring 
now that one person from the organization come to an annual training session that will be provided by 
IDEM around the state. Before, we held only one in Indianapolis and it was equally inconvenient for 
everybody in the state. To get from Evansville to Indianapolis requires a three and one half hour drive. If 
you are in one of the comers of the state it would require a long drive, and, as cleaners know, it is hard to 
get away from the plant sometimes. 

We also are requiring people to report on drycleaning, wetcleaning, and solvent mileage to 
CTAP, and IDEM. That is really to get an idea of where we are in the state on solvent mileage. We don't 
yet have good environmental indicators. You do not have to post it m the front of your store as the five- 
star cleaners will be required to, but you are required to track it. As I said, we don't know where people 
are. 


We are calling the industry average 300. Is that accurate as far as you're concerned, solvent 
mileage, 300? You have to factor in cleaners who are limping along at 100 or 200. Most cleaners are 
doing four and five and six now, but Elden would disagree, maybe. 

I guess we'll talk about the last page. On the four-star, the 450 solvent mileage figure was always 
in there at the four-star level. We decided not to bump that up, after much discussion with the review 
committee. That is a tough one. Most people are clustered in the three, four and five-star level. 

Quite honestly, one of the big reasons we didn't address that is because so many people are at the 
three-star level. We had so many cleaners at the three-star level, and we felt what was holding them back 
was that 450 number. Of course, we encourage people to promote themselves and get themselves from 
three to four to five, but we felt that because there were so many people at three stars, we thought we 
would go ahead and leave it at 450. We do require them to post the solvent mileage in their stores. 

Do customers really know what solvent mileage is? Probably not, but that is probably our fault 
as much as anybody's. We haven't educated the public on what solvent mileage is and how important it is. 
That is the bottom line on the recognition program. We are driving efficient use of drycleaning solvent, 
quite honestly. We want cleaners to get the most they can out of their drycleaning solvent. 

The five-star level has changed quite a bit from the first two years. We are now requiring a five- 
star cleaner to be a CED or have other environmental certifications acceptable to us, perhaps like the 
NCA-I program. If we had any drycleaners who wanted to become a CHMM, or a certified hazardous 
materials manager, that would be fine. That is a very challenging task, much along the lines of—maybe 
not as hard as a CPA, but it is very challenging in the environmental field. 


57 





Then we ask them to demonstrate their environmental leadership to the five-star review 
committee. Past examples included converting the vans to run on natural gas, exceptional solvent mileage 
in the 1,200 to 2,000 range per gallon of solvent, elaborate spill containment systems in drycleaning 
rooms, high percentages of wetcleaning. Those kinds of items are all the justifications that have to be met 
to receive the fifth star. 

A five-star cleaner now also has to get 750 solvent mileage, which isn't particularly aggressive, 
considering the new machines. But we still have to keep it fair enough so that, if you have a third or 
fourth generation machine and you're doing a lot of wetcleaning, you can still achieve that. If you can't 
do the 750 because you have an old machine, or you just can't get your wetcleanmg up, but you are 
maybe at 600 or 500—in other words, you're above the 450, but you cannot achieve the 750—we are 
requiring you to mentor five other cleaners. 

This is a new concept this year. We don't know how many people will take advantage of it. But 
even if we just get one or two to do it, we feel that the state has benefited, because five or ten other 
cleaners are now being helped by a five-star cleaner to achieve high solvent mileage. You never know 
what you're going to find when you go into a plant. Perhaps these five-star cleaners could find some 
disastrous situations that they would be able to help that cleaner through. 

So that is the application. As I said, the newspaper article was something that we do internally 
just to get the word out. It has a mailing list now of about 15,000 people across the state. The map was 
something that we do, and we will be taking that to state fairs and related events. 

I do want to talk about a couple of the challenges and the successes. At the nsk of sounding 
wishy-washy, I think it has been successful. We have built a relationship with cleaners in Indiana. As I 
said, a star doesn't get a cleaner out of enforcement, but it does help to have a relationship with Paula 
Smith, who started the program back in 1995, and with me. 

Sometimes enforcement doesn't get the rule right. I know that would be shocking to everybody in 
the room, but actually, we in some instances are able to intervene on behalf of a cleaner. We can't be an 
advocate for the cleaner, but we can sometimes explain the rule. 

That has two effects. Sometimes we have to remove cleaners from the five-star program because 
they aren't in compliance, they were clearly in the wrong, and then sometimes we are able to keep them in 
the five-star program and perhaps work it out with enforcement. 

Now, that gets us in trouble from an internal standpoint, because they think we are taking sides 
with the cleaner. I say I'm not on the cleaners' side, I'm not on the enforcement side; I'm on the side of the 
rule and what makes sense. Sometimes we enter into an enforcement action in error. 

Let’s discuss the challenges of the program. I see the big challenge of the program as getting 
more cleaners involved yet making sure it maintains its level of high quality. 

We conducted a survey recently, and asked how many people were familiar with the five-star 
program. Only about 7 percent said they were familiar with it; 93.1 percent didn't know about it. So that 
is one of the challenges. Then on the same survey, it said, how likely would it be to drive 10 minutes 
further to a five-star cleaner, and about 63 percent were either very likely or somewhat likely to drive 
another 10 minutes further to get to a five-star cleaner. So you see the dichotomy. That is the good news. 


58 


This is the bad news: nobody knows about the program, but they do like to see people that are doing 
what they can for the environment. 

The other challenge, I would say, is making it tangible to the cleaners to join the program. This is 
a five-star cleaner in Indianapolis. He is really using the program in his marketing. He puts hang tags on 
his bags, on his garments and shirts. He uses it in his couponing. He is really using the program to set 
himself above the market. 

However, he is in Indianapolis, a competitive area. If you are the only game in town, there is not 
much incentive to get into the program. 

Those were some of the challenges and some of the issues that we will be working through in 
1998 and 1999. 

Thank you very much. 


59 




Drycleaning Issues Facing the Armed Forces 

Joseph J. Nilsen 
U.S. Department of Defense 

Joseph Nilsen is a 15-year Federal employee with experience in several pollution 
prevention programs including the Hazmin Program, the Non-Government Standards 
Program, and the Technology Modernization Program. He currently is serving with the 
Directorate of Clothing & Textiles in the New Technologies Commodity Business Unit 
where his responsibilities include all specialty programs in the directorate. 


Good morning. I hope my speech for you today will be both entertaining and informative. As 
everyone here knows, my name is Joe Nilsen. I'm from the Defense Supply Center, Philadelphia. 

I would like to speak to you today about what we are doing in the military community in regards 
to acquisition reform, changing the way we do business, how we operate, and most notably, our efforts in 
partnering with the Environmental Protection Agency in giving our customers, the military services, the 
war fighters, the Army, Navy, Marine Corps, Air Force and Coast Guard personnel whom we serve as our 
customers, a choice in how they have their garments cared for. 

What is the most visible thing about Washington this time of the year? 

Cherry blossoms. What do cherry blossoms symbolize? Color. What does color mean to the 
military services? The color means a lot to the military services. Those color shades that you see military 
personnel wearing have an identity. They also have performance characteristics. 

In terms of performance, has anyone here heard of reinvention of government? Well, let me tell 
you, it is really happening. I can attest to that. 

See this coat? Prior to acquisition reform, this coat could have been described in a military 
specification. How many people know that word, MILSPEC, right? I'm here to tell you right now that 
the word MILSPEC in the military community and in the federal community no longer exists. If there is 
anything I can teach you today, it is that military specification is no longer used in the federal vocabulary. 

The words that replace it are "performance specification" and "detail specification." What we are 
seeking to do and what we are doing in the military community, because the train has now left the station, 
is to no longer use MILSPECs. We are using specifications and product descriptions in terms of 
performance. Some of those performance descriptions do have detail. However, the word military 
specification no longer exists. 

I represent the technology modernization program that focuses primarily on the revolutionary 
change in the way we describe what we want to provide for our customers, the military services, in terms 
of product descriptions. Because we no longer use MILSPECs, we are now using performance-based 
acquisition documents. 

With regard to that concept, we have formed a team that includes the military community, our 
customers, the academic organizations that work with us, and the industry. They meet at our organization 


60 


once a year in a main industry subcommittee meeting and also at other times of the year. Right now, the 
concept is in the 28 subcommittees that currently exist. The purpose of these meetings are to take these 
end items—coats, shirts, hats, whatever it is that we procure for the services that are in clothing and 
textiles—and look at the existing document and change the way they are described in terms of 
performance. No more detail. We don't have to tell the manufacturers how to make something; they 
already know. We just have to tell them how we want it to perform. 

We do that at our annual conference. Our annual conference is being held this year in 
Philadelphia, at the Pennsylvania Convention Center, on June 9, 10, and 11. 

What are we doing in terms of acquisition reform? We are doing a lot. Federal Standard 191 has 
206 test methods. That is a lot of non-government standards; it is a big program. We are 95 percent done 
converting it to a group of industry associated standards. 

Federal Standard 751, a guidance document used in the manufacture of garments, has been 
completed. It is an ASTM type. We expect to have the final document ready at our June conference. 
CF-206, felt document, and Fed Standard 311, leather test methods are all documents that at one time 
were unique military types that are now being converted to industry type documents. We anticipate 305 
protected adoption notices that we will be doing in our partnership with industry, and taking these federal 
documents and using industry accepted ones. 

Then there is acquisition reform, the way we do business, focusing on what we're doing now in 
terms of hazardous minimization. The President signed a series of orders four years ago that enables us in 
our acquisition process to remove all hazardous components that we require of manufacturers and use 
more environmentally accepted type alternatives. That is basically what we are doing now. We are doing 
that in our military service and test methods, and are going to include them in our solicitations. 

We are replacing some of these documents with what we call a nugget. Instead of using an 
associated component spec, we are converting it to a performance description and allowing the 
manufacturer to meet those needs. 

We talk about drycleaning in the military community. Well, basically drycleanmg establishments 
at military installations are small businesses. They sign agreements with military organizations to come 
on board and do business. Members of the military organizations that have uniforms historically are 
drycleaned. Being involved in this program and speaking to representatives of EPA and industry, the 
question posed to me was, perhaps there might be an opportunity in the military community to provide 
them with information regarding wetcleaning. My response to that is, perhaps. 

We also have to educate the military community about wetcleaning. We have to make them 
aware of what wetcleaning is and perhaps how it can perform as an alternative to drycleaning. But in 
order for us to do that, we have to prove that it is feasible. 

How are we going to do that? Our plan is simple. We're going to request that our customers in 
each military service clean two samples of one type of dress uniform that historically is drycleaned. 

We're going to take those five sets of uniforms and send them to a local drycleaning and wetcleaning 
establishment. At that time, one sample garment from each service will be wetcleaned and one will be 
drycleaned. At the completion of the cleaning cycles, we will bring the garments back to the Defense 
Supply Center in Philadelphia and evaluate them on several specific factors, such as colorfastness, 


61 




elongation, puckering, and seam strength, using industry-accepted test methods from ASTM and ASTTC. 
They have representatives here today, which encloses all partnership with industry in how we are going to 
evaluate drycleaning compared to wetcleaning. 

We will give the results to our military customers and, if an agreement is reached, we will then 
proceed to educate the military community about wetcleaning and exactly how it can be an alternative to 
drycleaning. Basically our plan is to educate the organizations, whereupon the completion of the tests to 
provide the military services with the results of the tests on the garments that they have, and therefore 
give our customers the desired choice that they seek as an alternative to drycleaning. 

This concludes my presentation. 


* 


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Fabricare Resources for the 21st Century 


Sylvia Ewing-Hoover 
Center for Neighborhood Technology 

Sylvia Ewing Hoover joined the Center for Neighborhood Technology in 1995 to lead the 
outreach and education arm of the USEPA funded Alternative Clothes Cleaning 
Demonstration Project. Ms. Ewing-Hoover is responsible for the dissemination of the 
results of wet cleaning research conducted over a 12-month period at CNT's 
demonstration shop, The Greener Cleaner in Chicago. 


I want to talk a little bit about CAMP. It is a public-private venture to answer more questions and 
get a better sense of how wetcleaning works in a situation where you have an existing cleaner with long¬ 
time ties to the industry, with a large body of knowledge. 

These charts are part of your handouts. Let me give you just a sense of some of the information 
that they have available. This is a 14-week period. They are using (word lost) machines. For all of us 
wetcleaning wonks who keep up with the latest equipment, this is the cheapest equipment that you can get 
at this point that will allow you to move beyond what a commercial washer can do. They also have one 
of Leroy Trevine's Millnors, but it is an older model, I believe. They have the American dryers and are 
going to move to Unimac equipment. 

The Rehorst staff had two training sessions with Ann Hargrove. CNT has worked with them to 
try and facilitate finding answers, as well as making Bob's work a little easier. They want to provide 
research data and business reports and have received support from the Lake Ene Protection Fund. They 
also have found that wetcleaning was a little easier than they had anticipated. They are at a level of 
wetcleaning at this point where they haven't yet maxed out. They are under 30 percent, I believe, so the 
equipment that they are using is effective and they are getting their skill level up. They will be able to 
provide us with information on both their water use and what it looks like in a scenario where you have an 
existing cleaner who is increasing the amount of wetcleaning that they do. Therefore, they are decreasing 
perc, but haven't yet embraced wetcleanmg as 100 percent technology. There are many paths to the top of 
the mountain, and people can make their personal business choices about what is good for them, but this 
kind of data helps them to understand what the options are. 

Let me just point out that the production costs associated with wetcleaning have been very 
favorable. You can see on the chart a little bit of that, but I urge you to talk with Mary and get more 
details, because it is not fair for me to pontificate about their research. But I thank her for doing the 
research, and I thank Bob Rehorst and his whole crew, because very often the owner will say, I want to 
try something new, and the employees are saying, my boss has lost his mind. But we see attitudinal 
changes and acceptance as wetcleaning use grows. 

I just want to remind you that those attitude issues—this is what I hope you take away from what 
Vic Vandermolen had to say from Canada: attitude issues can mean everything. How we embrace the 
future, how we respect our diverse opinions and how we move forward, baggage and all. 

This map gives you a sense of how around the country there are resources that are available. If 
you look in the southern region, Carolyn Swasz has got the Blue Ribbon fabricare center, where she is 


63 






prepared to do wetcleaning training, she is working on reinex or glycol ethers, and is a resource. You also 
have the trade associations and their training centers. 

The shaded states—California, Illinois, Wisconsin and Indiana—also have the environmental 
incentive programs, where partnership is encouraged, where pollution prevention methods are agreed 
upon by stakeholders, and where there is a market edge or marketing incentive to say to cleaners, "Do 
this, because it makes good business sense." 

So you can see that there are big gaps in the country in terms of resources, but we are hoping that 
is going to change. For example, the small business development centers of the SB A, which is part of an 
agreement under the auspices of that association, at trade shows around that map, cleaners will have 
access to the latest information on wetcleaning, alternative technologies, resources, and good perc 
housekeeping. As it exists now, perc needs to be handled responsibly as we strive to reduce it. The 
SBDC will help spread the tentacles of information a little further around the country, as will the key 
program that I mentioned earlier. 

We also hope in Illinois to soon have one of the first CO 2 machines. A cleaner there is expecting 
to complete negotiations next week to have a machine in his shop in Lansing Cleaners, and we will be 
there to see how that works out. Of course, Illinois is the home base for Ann Hargrove. 

You can't see on this map is how in Canada, there is a growing body of information available to 
cleaners and a growing body of partnerships, as well as in South America. We get requests every day 
from people in Mexico and other Latin American countries who are looking at our model of pollution 
prevention through alternative technology. 

Some of you may know, I have had a dual career working with media, so I would like to talk 
about how attitude and communication and media can affect things. You are allowed to laugh. What it 
says is that consumer education leaves a lot to be desired. 

This is an illustration of a woman watching her television and the newscaster says, brassieres of 
death, film at 11. It is a little bit of the sensational information that is available that doesn't do anybody 
any good, and doesn't provide solid information that people can make decisions on. While, yes, there is 
sensationalism, we all have to work together to make sure that real information gets out, that real reports 
are respected and read. We need to make sure that cleaners get an opportunity to make their own 
decisions and come to their own conclusions, and that the things that the various stakeholders do agree 
upon are communicated. As progress is made, that is the best way to go forward while acknowledging 
that some differences exist. 

This sheet that talks about wetcleaning pros and cons is an example of what we hope is solid 
information. Wetcleaning is a technology that is something old and something new. Yes, cleaners have 
always used water, but the new equipment, soaps and knowledge make what you do in water easier and 
the range broader than ever before. 

We have tried to talk about some of the areas that are problematic that research has pointed out, 
some that are still in development in terms of improvement, and some of that are positive and need to be 
acknowledged. I hope at your own leisure that you take a few minutes to take a look at this and, as 
always, we welcome your comments, feedback, and never criticism, because I know you don't have 
anything critical to say. 


64 


We have a wetcleaning information request form that I want to share with you. It shows the 
wealth of information that is already out there, from EPA information to the executive summary of the 
UCLA work, a wetcleaning equipment report that tells you all of the soaps, equipment, unbiased options 
that are available from a variety of companies. As this industry moves forward and as the stakeholders 
move forward, it is important to be aware of diversity and not just talk in a negative way about the 
changing face of the industry as Ed Barlow talked about the changing demographics, but embracing it 
positively. That is something that we try to do. 

With the help of KYCC, we have our information in Korean. It is exciting to know that it is 
saying what you want it to say because, thanks to the help of KYCC, we were able to translate this. We 
urge all of you, make your information accessible in different languages. Do that outreach, help bring 
everybody to the same level of information, and have equal access to information. We also have the 
equipment report I mentioned to you in Spanish as well. 

In conclusion, we have a great opportunity to move forward. We've got the next wave of people 
from CAMP and TURI and other organizations, Ann Hargrove and Associates, who are ready to help 
make fabricare in the 21st century easier and more successful, so that people can succeed and thrive as we 
move into the new century. 


Thanks. 




Mar-26-98 02:37P 



Wet Cleaning Resources 

Center for Neighborhood Technology • 2125 W. North Ave. • Chicago, IL 60647 
773/278-4800 ext. 299 • 773/278-3840 fax • http://Ww.cnt.org^us_man/Wet_dn.htrnl 


Ann Hargrove and Associates 

POBox I 
Lyons, IL 60534 
708/447-0879 

• The Fundamentals of Wet Cleaning 

• The Wetcleaner Newsletter 

• Training and Start-up Consulting 


Occidental College 

PPERC 

1600 Campus Rd. 

Occidental College 

Los Angeles. CA 90041-3314 

213/259-2566 

• Pollution Prevention in the Garment Care Industry: Assessing the Viability of Professional Wet Cleaning 
[Report on the Cleaner by Nature wet cleaning demonstration project] 


Korean Youth and Community Center 

680 South Wilton Place 
Los Angeles, CA 90005 
213/365-7400 

• Cleaners Assistance Program 

[Wet Cleaning Information and Resources in Korean and English] 


Toxics Use Reduction Institute 
University of Massachusetts-Lowell 
One University Ave 
Lowell. MA 01854 
508/934-3050 

• Wet Cleaning Training Curriculum 

• Training for Government Officials 




Mar-26-98 02:37P 


CAMP 

18554 Haskins Road 
Chagrin Falls, OH 44023 
216/543-7303 

• Wet Cleaning Research 

Environmental Protection Agency, Garment and Textile Care Program 
Pollution Prevention Information Clearinghouse 
401 M Street, SW. (7409) 

Washington, DC 20460 
202/260-1023 

• Wet Cleaning 

[Listing of Wet Cleaners in the United States and Canada] 

(EPA744-K-96-002) 

• Proceedings: Apparel Care and the Environment -Alternative Technologies and Labeling 
[From the September, 1996 Conference] 

(EPA744-R-96-002) 

• Resource Guide for Garment and Textile Care Professionals 
(EPA744-K-96-004) 

• Web page: http.7Avww.epa.gov/opptintr/dfe/garment/garnnent.html 

The following organizations offer wet cleaning classes. 

Please contact them for dates, locations and fees. 

Blue Ribbon Fabricare Center 
165 County Road 35 
Jemison. AL 35085 
205/688-2414 

Cuyahoga Community College 
FabriCare Technology Center 
2237 St. Clair Avenue 
Cleveland, OH 44114 
216/987-3700 

International Fabricare Institute 
12251 Tech Road 
Silver Spring. MD 20904 
301/622-1900 

Neighborhood Cleaners Association-International 
252 W. 29th Street 
New York, NY 10001 
212/967-3002 






Mar-26-98 02:36P 


TABLE 5 

HISTORIC PERSPECTIVE: WET CLEANING IMPACT ON PRODUCTION COSTS 
AS A % OF TOTAL SALES, 1996 AND 1997 

(WET CLEANING EQUIPMENT INSTALLED IN AUGUST & SEPTEMBER 1996 & 1997) 

(Source: Reehorst Cleaners Records) 


W4akTEfldfnfl 

-Previous VMf~ 

: Prevtou* T«r ~ 
~-%*ir«luctfon r 

-.'•••-.w -.V • • • 

-TW#y«rr::: 
- : T$t*f Pieces 

» *•••.'♦•< •• * *■ 

"thla Y«r% 
-Production 
Coat* to £aJas 

9-21-96 

9-20-97’-* 

2.958 

40 06 

3.209 

41.48 

9*26-96 

9-27-97 

3,173 

39.17 

3.476 

36.27 

10-5-96 

10-4-97* 

3.055 

41.11 

3.236 

40 80 

10-12-96 

10-11-97 

3,003 

41.40 

3.107 

43.59 

10-19-96 

10-18-97 

2,740 

46.19 

2,878 

42.66 

10-26-96 

10-25-97* 

2,905 

41.20 

3.108 

42.00 

11-2-96 

11-1-97* 

2.826 

38.49 

3,284 

35.62 

11-9-96 

11-8-97 

2,876 

39.62 

2.997 

40.24 

11-16-96 

11-15-97 

2.588 

39.77 

2.736 

41.22 

11-23-96 

11-22-97 

2.955 

39.00 

2.874 

37.48 

11-20-96 

11-29-97 

2.368 

39.40 

2,320 

38.52 

12-7-96 

12-6-97 

2.917 

36.75 

2.848 

37.49 

12-14-96 

12-13-97 

2.774 

38.78 

2,607 

40 84 

12-21-96 

12-20-97 

2.680 

40 92 

2,837 

39.30 

TOTALS 

39818 

40.13 avg. 

41517 | 

39.82 avg. 


NOTES: 

' On 8*30-97, the two Daewoo wot cleaning machines were installed 

: On 9-20-97 three UniMac programmable dryers were installed, two 30 pound and one 50 pound 
1 On 10-4-97 Ann Hargrove conducted her first wet cleaning training session 
4 On 10*22-97 Ann Hargrove conducted her second wet cleaning training session 
s On 11-1-97 the CAMP wet cleaning project officially begins 


Results from The CAMP Organochlorine Project 
Presented by research partner CNT 
for EPA Conference 
























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A Comparative Evaluation of Wetcleaning and Drycleaning 

Robert Gottlieb, Ph.D. 

Occidental College/UCLA 

Dr. Robert Gottlieb is currently a professor of environmental studies and environmental 
policy at the University of California at Los Angeles. He is the principal investigator and 
co-author of Pollution Prevention in the Garment Care Industry: Assessing the Viability 
of Professional Wet Cleaning. 


I'm going to spend the bulk of my time talking about a project that we undertook, that took about 
two years, called pollution prevention in the garment care industry. It was a research team involving 
several researchers. Peter Sinsheimer, who was a senior research associate on the project, is here. 

It was an evaluation undertaken by a center called the Pollution Prevention and Education 
Research Center. PPERC as its acronym is known, is a interdisciplinary center. It is a research education 
and outreach center. It is based both at UCLA and Occidental College. It is engaged in a series of 
research projects and it has an affiliated center that does work on sustainability issues. It has staff in 
Sacramento and Washington, DC. 

The key to some of our research projects is that we try and look at opportunities for pollution 
prevention and evaluate the context in which those technologies are being introduced and the real world 
circumstances in which they will be utilized. 

The wetcleaning project that we undertook in the fall of 1995 had an advisory board that included 
cleaners from the California Cleaners Association and the Korean Cleaners Organization in Los Angeles, 
people from the apparel industry, community groups, government agencies, and environmental 
organizations. We had collaborators on different parts—components of the research and evaluation, as 
well as the demonstration component of the project. We were funded primarily through the 
Environmental Technology Initiative of the Office of Research and Development at EPA. 

This project involved an intensive case study of a commercial wetcleaner, a startup cleaner that 
began operations in February of 1996. It was also a comparative evaluation that looked at wetcleaning 
and drycleaning from a variety of different evaluative methods. We also did the comparison, the 
evaluation in the context of other evaluations that occurred, and integrated the results of our comparison 
with those others that had been already undertaken. 

The research components were based on three fundamental components: performance, finances 
and the environment. It was a real world scientific evaluation, and I want to emphasize that. It was not a 
beta study. This was a cleaner that began for business, operating in real market terms. It was a viability 
assessment looking at the commercial viability of the startup cleaner, and then the comparison in relation 
to real world drycleaning cleaner situations. It was also an evaluation that was different from an 
exclusive laboratory analysis. 

We had two central research questions. Is cleaner by nature a viable business in relation to the 
different components of the assessment? And is professional wetcleanmg a viable pollution prevention 
alternative to drycleaning in real terms at this moment in time? 


66 


You heard Deborah Davis yesterday from Cleaner by Nature. This was the startup cleaner. It 
was a private commercial facility, organized as a 100 percent wetcleaner. It had an agency operation, had 
a facility in Los Angeles and a drop store in Santa Monica. The formal evaluation period was from the 
moment the store opened in February 1996 through its first year of operation, although there was 
information gathered and analyzed subsequent to the demonstration period as well. 

What you will notice is, as a startup cleaner, this is in terms of garments cleaned per month; the 
performance and activities at the store increased over time. That has been a trend that has continued in 
the post-demonstration period. In fact, just last week a second agency store was opened as a consequence 
of the increased performance. 

In terms of the performance evaluation, the first component was a profile of the customer 
garments. We also were interested in problem garments. We did a repeat clean test. We had a wearer 
survey based on wearers who participated in the repeat clean test and the survey of their responses to the 
clothes they were wearing. We also had two sets of customer satisfaction surveys. 

This was an integrated evaluation. It is important to note that the different components of the 
evaluation helped create the basis for doing an overall assessment of viability. 

In terms of the profile, Cleaner by Nature functioned as a typical drycleaner in terms of the kinds 
of garments that came into the store and that were cleaned. Sixty-seven percent of those garments were 
dryclean-only garments. That percentage breakdown broadly corresponds to what you will find in a 
typical small drycleaning operation. 

In terms of problem garments, we found that, as a startup cleaner with the new technology, 
certain trends came into place. The primary one trend was, as the cleaner developed expenence in the 
technology, the types of problems defined, for example, as redos or problems associated with claims or 
store credit, decreased over time. There was a slight increase in the number of garments that were 
rejected. That actually paralleled the information about increased expenence improving the ability to deal 
with problem garments. If you see a garment that had a problem that would be rejected by any cleaner 
because of the nature of the problem, that was the decision that was made. 

But the numbers are very small. We are talking about for example, in terms of claims and store 
credit, a percentage of 4/100ths of a percent. In actual numbers in the post startup period, there were 
three claims out of 29,000 garments. In terms of the year-long evaluation, there were 14 out of 45,000 
garments with claims and store credit problems. 

Another component of the evaluation was the repeat clean test that involved 40 sets of dryclean 
only garments. The selection was designed to identify garments that would give potentially the most 
problems for wetcleaning. They were selected in conjunction with members of the drycleaning industry 
who were on our advisory board. There were six wear-ins. We used ACCT criteria, in terms of the 
evaluation. The California State University lab at Long Beach was used. The test was also triple-blinded 
in terms of the basis on which the evaluation took place. 

There are substantial details that I urge you to look at in the evaluation, and the methods are 
described in the appendices. One key area, of course, that is on everybody's mind has been dimensional 
change. 


67 




In terms of the repeat clean test component, we found that there was slightly greater shrinkage, 
both lengthwise and widthwise in wetcleaning and a very small amount but slightly greater stretching in 
drycleaning. There was a normal distribution in terms of the dimensional change, although it skewed 
more in the area of shrinkage for wetcleaning and drycleaning. 

In terms of general appearance, a series of different criteria, some of the key categories. With 
regard to the proportion of garments with technical problems, in wetcleaning you have more problems 
that are detected. Again, the number of problems detected are small, but you do have more problems in 
terms of color issues, color migration, consistency, and pressing quality in wetcleaning than in 
drycleaning. You have more problems in stain removal and damage to garments in drycleanmg. 

This, as I mentioned earlier, is in the context of wearers who were wearing clothes. They were 
also blinded and didn't know what clothes they were wearing. They wore the identical set of garments. I 
should have mentioned earlier, we had three sets of garments that were identical; one went to the dryclean 
shops, one went to Cleaner by Nature, and one was a control garment. 

After the fifth wearing we did a survey of the volunteers. We found essentially that the results 
showed comparability with the repeat clean test results as well. Wetcleaning was detected in more cases 
in terms of shrinkage problems. In pressmg problems, drycleaning had more problems in terms of 
stretching and damage to the garment. 

Customer satisfaction was a key component of the performance evaluation. This is a service 
business, and how customers respond adds significant information in terms of evaluating and assessing 
performance viability. For the Cleaner by Nature survey, it was a block random sample and 180 surveys 
completed, a very high response rate. We used the same survey area, using telephone prefixes as our 
area for developing the response. It was a random sample. We had 100 completed surveys and a parallel 
questionnaire. We had not as high a response rate, but still a significant response rate for the survey. 

The customer satisfaction surveys, were broken down in terms of this cart into two areas. One is 
the positive performance attributes that customers were asked about. Then a set of negative performance 
attributes were presented. Questions included how the respondent felt about the cleaning of the garment; 
if he or she felt positively sometimes, frequently, or always; and similarly if there were negative problems 
that could be determined by asking how you felt about the cleaning of the garments or issues around 
stretching or shrinkage, sometimes, frequently and always. 

The results show some key variables. For example, in the cleaning of the garment, 96 percent of 
wetcleaning customers felt that frequently or always the garment was cleaned. In drycleaning, the 
response was 79 percent. The major discrepancy area in the positive performance area is in stain 
removal, with 79 percent in wetcleaning and 49 percent in drycleaning. 

On the negative performance attributes, in shrinkage 26 percent felt that there were problem areas 
for wetcleaning; 19 percent thought there were problems for drycleaning. In nine of the 10 areas in terms 
of customer satisfaction, there was either equal or greater satisfaction with wetcleaning and drycleaning. 
Also parenthetically, one should note that there was high satisfaction for both processes, for example, not 
on this chart. To a question, would you recommend your cleaner to a friend, 93 percent in wetcleaning 
said they would and 87 percent in drycleaning said they would. 


68 


The second aspect of the evaluation is financial obviously key in determining viability issues. In 
the case study component we had a startup cost analysis, a profit and loss analysis, and we looked at 
pressing productivity issues. In comparing wetcleaning and drycleaning, we looked at equipment costs in 
terms of the startup costs, equipment costs, and maintenance costs. We did a pressing time comparison 
and we also did an overall cost comparison. 

In terms of the case study, this is an income statement that in effect characterizes the revenues 
and expenses that are occurring at Cleaner by Nature on a quarterly basis. There are two key things to 
understand about this slide above and beyond the specific issues around the fact that your average pieces 
per day are increasing significantly. This parallels, of course, what is going on your revenue side. So you 
are seeing a change m performance in terms of financial performance, so that by the fourth quarter there 
is a small profit. That trend actually continues into the post- demonstration period. You not only have 
substantially higher profit margins in the second year; but in the demonstration penod your revenues are 
increasing significantly higher than your expenses are over time. You are, in fact, realizing greater 
efficiencies as your number of garments cleaned increases, in terms of the kinds of costs and expenses 
that one would have. 

In terms of the comparative evaluation—equipment costs - the wetcleaning equipment is less 
expensive than the drycleaning equipment. However, if you include pressing equipment—in this case, 
the purchase of special tensioning equipment meant that there were greater costs in that category for 
wetcleaning than drycleaning. 

The total costs are relatively comparable, but slightly greater for drycleaning. In terms of 
maintenance costs, we found that the costs for drycleaning equipment over time are greater than in 
wetcleaning. 

Pressing is an area similar to dimensional change where lots of questions have been asked in 
relation to wetcleaning. We decided to do an evaluation where we had a senes of drycleaners 
participating with Cleaner by Nature. We literally had the stopwatch and we counted the number of 
garments per minute cleaned. 

There were some difficulties because the basis of that evaluation was the only one available to us, 
because we didn't have the same presser pressing the same garments. As many of the cleaners on our 
board told us, pressing is highly variable. Therefore, the numbers are going to vary depending on 
circumstances and cleaners. 

Environment Canada was able to use the same presser used for the same garment, and we also 
looked at their results. In both cases you have more time required in wetcleaning than in drycleaning, 
although there are differences if you take into account the difference in the pressers. 

That leads to what we defined as process dependent costs. In other words, there are costs for both 
wetcleaning and drycleaning that will be the same. They might vary in terms of decisions that are made, 
but they are not dependent on the process. Of course process dependent costs will be identified if there is 
a selection of the different technologies. 

The major cost differential in this area is going to be in terms of the greater costs for wetcleaning. 
These will be in the labor side, particularly in terms of your pressing needs. On the other hand, for 
drycleaning, you have greater costs associated with the area around regulation, liability, and the cost of 


69 










the chemicals that tie into those sets of costs, and those costs are going to vary over time. Broadly 
speaking, we found comparability with tradeoffs in the process dependent cost comparison. 

Now, the third aspect of our study was the environmental assessment, and some issues have been 
raised here that I think come into play in terms of our assessment. We looked at water, both inputs and 
outputs. We looked at water use and wastewater discharge. We looked at energy use and at chemical use 
and output issues. We did a basic plant level comparison. We also scaled it to the regional level. 

In terms of the regional scale, the assumption was made that if every drycleaner in the study 
area—the service area of the South Coast air quality management district, or essentially Southern 
California—switched to 100 percent wetcleanmg, what would happen? That was the basis of the regional 
comparison as well. 

In terms of these evaluations we had partners with agencies that do monitoring, or that could 
provide the metering that was necessary to identify very specifically the information that we needed. So 
we had metenng taking place in terms of water and energy. We also had the drainage pipe for wastewater 
discharges monitored. We were doing the metering, the evaluation through the bureau of sanitation in the 
City of Los Angeles at that point at the drainage pipe. 

In terms of water use, our assumption was, unlike Environment Canada, that the water in the 
drycleaning equipment would be recirculated. So our figures are different from Canada. You do find 
greater use of water in wetcleaning than drycleaning, as would be anticipated. There are uses in 
drycleaning, but there are more substantial uses in wetcleaning. 

When you put that in the context of this regional scale model, the issue came up about what 
would happen in a water-dependent region such as Southern California, where you rely on imported water 
for your water source. Well, we were able to not only quantify what that meant, but we then discussed 
that with regional water planners from the metropolitan water district. 

I was on the board of directors of the metropolitan water district in the 1980s, and we calculated 
that the percentage would be the equivalent of a population increase of 3,000 people, if every drycleaner 
converted to wetcleaning. They felt this was not significant, particularly if you compared it with one 
small production well that is taken out of circulation because of contamination. That is the more 
significant amount of water lost. So they didn't see water usage as a significant environmental problem 
in the region in terms of a shift to wetcleaning. 

In terms of the wastewater analysis, we found that there were no problem areas in the permitting 
or the standards that had been established for pH, VOD, heavy metals, and so on. This was consistent 
with the Chicago study results as well. We were able, as I said, to evaluate it at the drainage pipe. 

In terms of energy use, there is greater use of natural gas in wetcleaning, but because of the 
pollution control equipment there is a greater use of electricity in drycleaning. Basically, the two are 
broadly comparable. In the regional analysis we also attempted to look at from an AQMD matrix, how 
you would translate that information into pollutant levels. 

Stated another way, natural gas is essentially a cleaner technology or cleaner source of energy 
than electricity. However, you had greater natural gas use in wetcleaning, so you're talking about broadly 
comparable energy use. 


70 


The big difference as you might expect was in chemical use. There was no waste sent out from 
the collection on the spotting board and the chemicals used in wetcleaning. We also evaluated the 
chemical use specifically in terms of their content. In drycleaning, there was a calculation based on 
AQMD in air resource board data. If you did that conversion, you were talking tons per day, for example, 
of a reduction of essentially 4.2 tons per day in terms of PCE emissions and of .4 tons per day in terms of 
hazardous wastes. 

Although we couldn't directly quantify a senes of factors, we still looked at them. They play a 
role in terms of thinking about if this technology is viable, if the operation is viable, and about what is 
going to happen in the future. You do have technology changes. This conference is talking about what 
could happen upstream. You have care labeling issues. 

These factors will influence these changes in terms of technology. There is a whole set of issues 
around marketing that needs to be explored. They will have a significant impact on the future of the 
different processes, as of course regulatory and legislative issues are going to come into play, on both the 
environmental and the financial side. For example, one of those new technologies, the form fitter and 
pants topper, has special tensioning equipment, which changes the dynamic. That was when we were 
able to incorporate into our analysis because we could look at that in relation to the performance 
considerations. 

There is one area in terms of these contributing factors that you could begin to quantify. We did 
that for this evaluation because, in California, there is no provision right now for state legislation to 
reduce the nsk of cleaner liability risks related to perc use. But several states do have laws on the books, 
and some but not all have been supported by drycleaner organizations. 

Wisconsin, for example has a gross receipts tax of 1.8 percent and a five dollar a gallon tax on 
PCE. Such additional costs in turn need to be incorporated into any evaluation of the financial viability of 
a system. 

Our conclusion, in terms of the case study, is that Cleaner by Nature is a viable business. It 
cleaned a full range of garments, and it clearly improved performance over time. There was strong 
customer satisfaction and increasing profitability. It has now expanded to a second agency site, and there 
is minimal environmental impact. 

In terms of the comparative analysis, our evaluation identified wetcleaning as a viable pollution 
prevention alternative. In the performance area, we feel there are challenges that remain in both 
processes. In wetcleaning, there are continuing issues with shrinkage. Some of these are garment 
manufacturing issues and technology issues that can be addressed; some are performance with expenence. 

Drycleaning, as has been pointed out in studies and discussions in the trades, has problems 
around stain removal and garment damage. But they are probably comparable in terms of the evaluation 
that we provided. 

Looking at financial issues, there are tradeoffs in wetcleaning and drycleaning. I think you want 
to think about the overall context and perspective. In wetcleaning, you do have higher labor costs, and 
you do have higher detergent costs. In drycleaning, you have higher equipment costs and higher 
regulatory costs. As I said, that is also a changing dynamic in terms of the contributing factors. 


71 









On the environmental side, wetcleaning is more viable. The environmental impacts are minimal 
on the wetcleaning side. They are significantly greater in drycleanmg, and can be measured specifically 
in terms of the chemical use issues. 

Where do we go from here? We completed phase one of our research. We feel there are 
significant issues of research, policy, and industry development that need to be addressed. 

In terms of policy, in the rulemaking processes at both the state and federal levels, how do you 
assess and evaluate where you put a wetcleaning technology in the rulemaking framework. In a broad 
statement, wetcleaning can be considered best available control technology. 

There are technical and financial issues. Every cleaner, wet or dry, obviously is interested in 
making opportunities available, particularly where it has decided to incorporate a wetcleaning system or 
switch to wetcleaning. 

There are structural issues. Care labeling is going to be discussed tomorrow. We had on our 
advisory board garment manufacturers and retailers. We have begun a process of working with them to 
deal very specifically with issues that can be addressed on the future of this process. 

There clearly needs to be wetcleaning facilitation. There needs to be quality control, as in any 
kind of service industry. That is an issue that needs to be developed and expanded. There needs to be a 
specific home for wetcleaners where they can not only share information, but also develop the kinds of 
tools, whether it is performance tools or the marketing tools and the financial tools that are going to 
facilitate the development of this industry. 

Part of our effort was also a demonstration project. In California we had intense interest by 
cleaners in a tour that the Korean Youth Community Center organized. We had about 30 Korean cleaners 
that came to the site. The dialogue with cleaners and others who are interested in wetcleaning has to occur 
and has to really be expanded in a number of different venues. 

Just one final thought. Pollution prevention, I think, can best be characterized as solutions that 
create opportunities for an industry. For cleaners, the presence of a viable pollution prevention alternative 
opens doors. It establishes, I think, a basis not just for survival, but for growth and sustainability, and in 
fact, I would argue, for peace of mind. 


72 


Taking an Industrial Ecology Approach to Garment and Textile Care 


Braden R. Allenby, Ph.D. 

Vice President for Environment, Health and Safety 

AT&T 

Brad Allenby is currently Vice President for the Environment, Health and Safety for 
AT&T. He has authored a number of articles and book chapters on industrial ecology 
and Design for Environment; writes a column for the Journal of Industrial Ecology ; is 
co-editor of The Greening of Industrial Ecosystems , published by the National Academy 
Press in 1994; and is co-author of several engineering textbooks, including Industrial 
Ecology, published by Prentice-Hall in January of 1995, Design for Environment 
published by Prentice-Hall in 1996, Industrial Ecology and the Automobile, published by 
Prentice-Hall in 1997, and Industrial Ecology: Policy Framework and Implementation, to 
be published by Prentice-Hall in 1998. The views expressed in these comments are the 
author's and not necessarily those of AT&T. 


The purpose of my remarks today is not to try to talk about drycleaning and fabrics. Rather, I'm 
going to try to establish a little bit of a context so that you can see how the very tumultuous kinds of 
things that are going on in your industry in fact are mirrored in a lot of other industries, and the 
implications are just as serious in those industries as they are in yours. 

There are two important principles that go a long way toward establishing this context. The first 
is that what we are talking about is not really environment. What we are really talking about is 
technology. That is important because, as long as people think they are working with environment, they 
have a tendency to slip into the old compliance or remediation mind set. Such a mindset treats 
environment as overhead, for both the firm and society. But if the changes caused by environmental 
issues are occurring in your base technologies, then you are dealing with strategic technology issues that 
are critical to your business, not just environment. 

The second related point is that environment is in fact moving from overhead—overhead is 
putting it over in a comer and letting somebody else take care of it, which is the way most companies still 
treat it—to strategic for the firm and for society as a whole. Part of that process is that environment no 
longer dominates the decision-making process. That is a difficult transition for people who work with the 
environment, and it is a difficult transition for the ordinary business person who has to think about 
environment in ways that she or he never had to before. 

So what does all this mean? Well, let me go through a little bit of it. I will offer some scenarios 
in doing so, not because they necessarily are what will happen, but because scenarios can help you think 
about what might happen and how you would adjust to them if they did happen. 

Let me begin by discussing some of the requirements of the Blue Angel ecolabel in Germany, 
which is now in place for personal computers. The first requirement, that personal computers be designed 
so they are modular and can be upgraded by the user, is a profound challenge to a design team. 
Functionality in a personal computer is very protean; it can reside in a lot of different places in the 
software-hardware system. So as soon as you tell me I've got to go to modular design, you're telling me 
I've got to begin freezing that functionality in different places in the computer. You're also telling me that 


73 





the interfaces between those modules have got to be robust enough so that the technology can be 
upgraded in unpredictable ways throughout that computer, and I can still maintain a working system. 
Moreover, this is a volunteer standard, so you're telling me that I've got to do all that and still compete 
with manufacturers that don't bother to do any of it. 

The result is a very profound design challenge. It has significant market implications as well. In 
this case, about two weeks after these ecolabel standards were put into place, NCR and a couple of other 
companies met the standards and, based on meeting the standards, were awarded a large contract from the 
government of Denmark which piggybacked their procurement policies on the ecolabel standards. The 
strategic and marketing implications of the Blue Angel are apparent. 

The point of this example is not computer design, but to illustrate the gap between environment 
as strategic, and the way we usually think about it. This is not the kind of challenge that you solve by 
working with a scrubber or by putting more water treatment plants in. This is profoundly strategic for 
anybody that manufactures computers and intends to compete in the global market. That is the difference. 
This is what environment is today. 

I'll take another example. Let's take one that is near and dear to my heart, a central server. A 
central server is basically a computer with a whole lot of memory that you can put in the network as 
information and entertainment are increasingly digital, pretty soon, you're putting all kinds of songs, 
films, performances, and even art on the central server with new broadband technology, you'll be able to 
access it in real time. In fact, next year there are going to be cars on the road that are fully equipped with 
Windows 98. (You think you've got problems with cellular phones wait until you're rolling down the 
highway in a PC.) 

What this means is that you potentially can achieve discontinuous environmental improvements 
in the data storage industry. Why? Because you dematenalize the CD and the tape industry. You no 
longer have to go out and buy a CD with one song that you like from Madonna and 15 that you don't. 

You just pull off what you want from the Internet in real time. 

So by substituting electrons for pressed plastic, you can achieve significant environmental 
benefits. However, think about the other implications of doing this. A whole sector of small business just 
got knocked for a loop. What happens to the people who owned video rental or music stores, or people 
who make and manufacture CDs? Where is that distribution chain? What about the shops that are now 
empty? 


The downsides of any technological evolution - for that is what it is - become clear in the 
example. We shouldn't think that this kind of technological change is going to be easy or painless. In 
fact, it is liable to be very, very painful for some people. One of the reasons that you want to study these 
kinds of scenarios as a private company is to try to understand where you are liable to get blindsided. 

You also want to study this as a society so that you can prevent or mitigate some of the pain that 
technological evolution is going to cause. 

Another interesting scenario illustrates another basic trend in our economy which has the 
potential for significant environmental efficiencies. Consider a very interesting shift in the auto industry. 
Companies such as PPG used to basically manufacture stuff, in this case, paint. And the more paint they 
shipped out the door, the more they got paid. So in fact, their incentive was probably to get people like 
GM and Ford to use as much paint as possible, right? 


74 


But then both the automobile manufacturers and the paint producers decided to try a new business 
model which offered both parties better value: rather than sell paint, the paint manufacturers would 
contract to provide a service, painted "bodies in white," or care chassis. 

As a result a sector that was previously offering a product, paint, is now offering a service, car 
painting, and getting paid on that basis. The process is being expanded, because it has been very 
successful. The savings to the car manufacturers have been substantial and the savings to the people that 
provide the service have been substantial. 

Now, what are the implications? First, if you thought your business was making paint and 
shoving it out the door, guess what? You just lost a critical customer, because these service contracts are 
locking in supplier relationships. 

More subtly, it used to be that my business plan was to make as much paint as possible. My 
business plan now has shifted fundamentally to trying to understand how I can paint cars with minimal 
liability, minimal exposure, minimal waste costs, and as little paint as possible. I am now a service 
company, and the people I hire are very different than the people I hired when all I did was manufacturer 
paint. One lesson of this experience has been, in fact, that service firms require different skill mixes than 
manufacturing firms. 

It is at least possible to develop a framework that can be used to think about some of these issues 
(Figure 1). The vision is sustainable development, but it remains a vision because it cannot yet be 
operationlized. 

There are at least three separate paths of evolution that have to occur as we begin to really work 
into these issues. The first is ethical and theological. For example, if you look at the climate change 
negotiations in Kyoto and why they were so rocky, it was not because of the science and technology; it 
was because the institutions to make Kyoto work do not exist. It was an institutional problem, not a 
science and technology problem. 

Industrial ecology is the field that tries to study these very difficult and complex multidisciplinary 
issues, which essentially amount to the impact of human economic activity on the environment. It may be 
thought of as "the science of sustainability." 

Assume that we provide companies and individuals can be convinced to do the right thing 
environmentally. The industrial ecology infrastructure then is the answer to the question: What do we 
need to provide as a society so that they can do so? 

At the most operational level, you have implementation at the firm level through things like 
Design for the Environment. Here, a whole set of tools relying on practices such as Design for the 
Environmental (DfE) and life cycle assessment are being created. It is not overhead, it is not compliance, 
it is not remediation. You are dealing again with a strategic dimension of technology driven by 
environmental constraints, not by remediation and compliance. 

I would like to close with a scenario for drycleaning that integrates some of the things that I have 
talked about (Figure 2). Remember some of the themes: the importance of technology and the shift 
between simply offering a product and offering a service. 


75 












One dynamic that is apparent in the figure is that the distances between different pieces of the 
supply chain collapse. Taking our previous example, PPG and Ford are now heavily dependent on each 
other. That linkage becomes very strong; for PPG and for Ford it is a win-win. For the people who get 
cut out of that, it is a significant loss. So you see, offering a service within which the product is 
embedded is beginning to replace just passing on materials. 

Turning now to dry cleaning, and the major environmental issue associated with existing 
technology, emissions of perchloroethylene. First consider technology options: You can do things such 
as better housekeeping and emission controls, working within your existing infrastructure. There are also 
some service options for reducing emissions. The most obvious is offering a pressing service without 
requiring cleaning. In many cases, people are happy with that. So there are things that can happen with 
only minor changes in the existing system. 

But now jump one up. Go to a future environment where you are looking at alternative cleaning 
technologies. Suddenly, the issues begin to get broader. The advantage of doing end-of-pipe stuff is that 
the impacts are pretty minimal if you make a mistake. You just put on a little bigger scrubber than you 
need or something like that. But once you begin changing process technologies, you have upped the ante 
considerably, because a process technology will be locked in for a relatively long period of time. So if 
you choose the wrong options, the economic and environmental costs are far greater. 

This also begins to lock you in to a larger network economically. It is hard to begin looking at 
alternatives without also looking at the fact that you as a dry cleaner become more dependent on different 
parts of the supply chain to make the changes. You are, after all, dependent upon the firms that make the 
cleaning machines, so they become part of the system. 

What happens? You may begin to form complex cleaning and garment management paths. That 
is to say, when somebody comes in, you take the garment and push it into the process that works best for 
that particular garment, given those particular circumstances, the equipment that you've got, the 
equipment that is available, and the kinds of products and materials that are available to use in that 
equipment. 

Finally, let's jump much further out, and look at what might happen with really fundamental 
technological evaluation. As most of you know, you can grow cotton now that has already got polyester 
in the fiber as it comes off the field. It is only a couple of percent, but the possibility of wash and wear 
right off the boll cannot be ignored. 

Think about somebody downstream perhaps, some large garment manufacturer that makes blue 
jeans, that suddenly says to itself, if people are going to start liking things that don't need to go through 
complex cleaning processes, I can begin to design my fabrics and my clothes differently. What happens? 
Drycleaning is getting awfully close to the Blockbuster scenario, to getting blindsided by technology that 
is coming out of a part of industry that you weren't paying attention to. 

So what happens? First, remember that this is only a scenario, there are a lot of things like 
cultural inertia which in practice make many such technology shifts problematic. A lot of people like 
wearing clothes that need to be drycleaned. They are used to them; they are comfortable with them; there 
is a pattern of habit that will tend to persist. It may take some time before any of this really happens, if it 
ever does. 


76 


If it should occur, everyone in the clothing industry will see a shift in the network of 
relationships. You're talking about going all the way back perhaps even to the people that grow the 
cotton. Or perhaps you even go back to companies like Monsanto, that now decides, in addition to 
making cotton that works with Roundup, they are going to start putting polyester in the boll. 

Obviously, there are enormous problems as soon as you get into these issues. For example, how 
does an industry characterized by very small operations deal with some of the other pieces of the supply 
chain that are so far away and have interests that are very different from the interests of the drycleaners? 
These are not easy questions to resolve. 

Finally, you've got the possibility that you evolve a new kind of service. A lot of people, 
particularly in urban areas, are going to like using a service that manages their garments, whether it is 
drycleaning them, just washing them, or perhaps even mending and maintaining them. The reason is 
affluence combined with diminished free time. Do they want to spend their one free day working on 
clothes? No. You begin to see the possibility that there are service options that can pick up and integrate 
some of these offerings, present a new and integrated service to the public that in fact, creates more 
demand rather than less. 

Figure 2 suggests some possibilities, but they are only illustrative at this point. The main value, 
as with any scenario, is beginning the creative planning process. How would you restructure your 
offering to cement your relationship with the end customer and make your service important to them by 
locking them in? What might work? Why might it not work? What is it that you really do? Do you 
need to form new alliances or business relationships to make it work? 

In the end, this is the value of the application of industrial ecology principles to the drycleaning 
industry: not just to resolve an immediate environmental issue, but to suggest new market structures 
where not just the customer, but every element of the supply chain enjoys enhanced value - in other 
words to build a better future. 


77 


Figure 1. Industrial Ecology Conceptual Framework 



78 


Organizational Change AT&T Matrix System Internal Systems Evolution 

(e.g., "green accounting") 













Figure 2. Industrial Ecology Scenario: Dry Cleaning Roadmap 



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79 































Setting Up a National Distribution System for a New Cleaning Technology 


Jack Belluscio, President 
Global Technologies 

Jack Belluscio is President of Global Technologies, LLC, since 1994. 


Thank you. Global Technologies was created to address many of the issues that we just heard 
from the executive from AT&T. When brought into an industry, technology cannot just be converted 
haphazardly without considering the implications of its impact on the industry, on how we present the 
new technology to government officials, how we present it to the marketplace. We also have to consider 
what its ultimate cost is, not only to the end user, in this case the small to medium sized businesses, but 
also to the consumer, and how we might be able to use technology to revitalize an industry. 

What I was asked to discuss today was not the technology that we are commercializing called 
Dry Wash, but our process of how we look at commercializing this technology. I thought it would be nice 
just to share some of the ways in which we look at technology. Our role is specific to defense technology 
conversion and transfer. 

In this case, my company is marketing the Dry Wash cleaning process and we are targeting the 
mom and pop operations. Our company wants to make sure that when we say that we have no hazardous 
chemicals, less energy consumption and better cleaning, that we are addressing the needs of at least 70 
percent of the marketplace. We have to make sure that we can not only sustain the needs of the industry 
today, but hopefully look towards some growth for the industry's future. 

We have a very specific process. This particular technology came out of the aerospace industry. 

It normally takes 15 years to have an aerospace technology come out of the laboratory and into a usable 
form. We have come up with methods of how to commercialize technology in a five-year period with 
five very specific steps. 

This is our commercialization time line. This particular technology came out of what was 
originally called The Hughes Aircraft Company. It has since been purchased by Raytheon Systems. 
Before it gets to product, a technology goes through its own life cycle. At Hughes Aircraft, it had 
investment and competencies far beyond or far different than anything that our own industry could pull 
off, so it has a very large investment in technology from the beginning. As time goes on, the technology 
provider reduces its investment. 

At the same time, it is a company like mine that encourages manufacturers of that industry to join 
the team and see how to share the technology and how to start their investment moving towards a final 
product, so that we have a smooth transition between technology and end product. 

In the commercialization business, we call this the valley of death. This is where most 
technologies fail, because the laboratory is developing something wonderful for an application, but the 
marketplace is not ready to accept it. This happens either because of lack of investment or lack of vision 
or because the competitive forces within that industry seem to be too great for one company to take on. 

So collectively, we understand this and say to ourselves, we have a good technology and we want to move 
it to the marketplace We say, what are we looking to do? 


80 


The life cycle of the technology is risky. Most people know somebody who is an early adaptor or 
an innovator. If we bring technology such as the Dry Wash to the market too soon, and we are only 
looking towards the early adapters here who are the top 10 percent of the industry, chances are good that 
the technology will fail. If the technology doesn't fail, then the industry will be hurt because 90 percent of 
the marketplace can't afford it, or doesn't know how to use it because it is too complicated. 

This is why we go through this process of assuring that when we release the DryWash 
technology, it will address at least 70 percent of the marketplace. We must look at the needs of the entire 
industry. 

There are approximately 150,000 drycleaning plants around the world. Each one of them is 
cleaning clothes, each one of them is using solvent, and each one of them has machinery. If we come up 
with a technology without this total industry approach to ecology, then we have failed in our mission. We 
must look at a whole product model when we are commercializing this technology. 

We have to look at the installation and the logistics. We have to make sure distribution is in 
place, because the sales and service is what makes it affordable for the technology. We have to make sure 
that we have system integration. The machine that we and our manufacturers produce must fit in the 
same location as the old machine. It must have a chance to improve the business. 

When we understand the different models that we are considering for our technology we come up 
with five specific steps that take a total of five years. But the technology must consider the industrial 
ecology point of view. It must consider the entire concept of what the industry is trying to do, and how it 
could help the business grow. The technology must be widespread, and it must be a better performer. 

And ultimately at the end of the day, we have to be able to make money with the technology. It has to 
have some economic benefit. It has to go beyond bemg environmentally sound. There are far too many 
consumer studies that say people love to be environmentally friendly, but they may not be willing to pay 
more for it. As my company moves forward, working with 14 manufacturers and sharing technology, we 
always have to keep that in mind. 

Step one was to create a technology for market needs. This was our first year. It was 1994, when 
you may have heard of the DryWash process coming to the New Orleans convention in '95. In '94 we 
created a technology group. On one side, we had Los Alamos National Laboratories with the support of 
the government agencies, such as EPA and the Department of Energy, helping to validate the core 
technology, which you know as DryWash today. 

On the other side was Raytheon Environmental Systems which was developing the technology. 
Between Los Alamos validating the concepts and Raytheon's scientific team developing the process, we 
were able to come up with a usable technology that we were able to demonstrate for worldwide services. 
Throughout this process, we had to maintain that easy-to-use concept. More importantly, the technology 
should not change the way we are doing business. We should not be saying we are going to pull out our 
old machine, or tie into some satellite store, or add a truck on the road that may be polluting more, or 
looking at another way of doing the business. 


81 





We have a good industry structure today, and it is our job at Global Tech to make sure that the 
technology uses that industry structure. That structure allows the industry to accept the technology and 
helps us to keep that mind set that we are looking at it from an industrial point of view. 

In year two, we introduced the technology in June of'95 at New Orleans. It was a laboratory 
bench model. That was the first time we allowed the marketplace to talk to end users, distributors, and 
manufacturers. We told the industry that there was another team on the case that was bringing technology 
out of the aerospace industry. 

In year three, we needed to demonstrate the commercial use. In 1996, we were looking at 
improving the performance of the carbon dioxide technology. We wanted to demonstrate that there was 
no hazardous waste in the process and that we had a way to expand the business for the future. 

Last year was our fourth year. This is where we had our commercial teams sharing the Dry Wash 
process. There was a demonstration in Las Vegas in 1997. Over 3,000 people came into our booths to 
meet the manufacturers of the process and to watch demonstrations. 

This is a very unique situation. We have major manufacturers sharing a portfolio of core 
technologies so that they can work on the industrial ecology concept. At the same time they work on 
applying the technology to the demands of the industry, which is unusual. For most technologies, the 
industry has to change to meets its requirements, which is something that we heard from our last speaker. 
But we have to look at it as a better performing solution, or it is not going to fly. Our customers, our 
industry participants, know that they need to pay the bills and make money; it has to be more than just 
environmentally sound. 

We are now in our fifth year. You will start to see DryWash units popping up. There are eight 
locations right now around the world that are using it in a test mode. They are not only perfecting the 
machinery, but the DryWash fluid and the chemical additives. Chemical companies offer a full line of 
chemical additives that are hazardous waste-free and that are not dangerous to workers. Manufacturers 
such as Electrolux, Raytheon Commercial Laundry, and Comico are all working on their designs. They 
are all working on how to meet the current needs of today's machinery. 

Caled Chemical, Sales Star, and a few other chemical companies that asked not to be mentioned 
today, are all helping my organization work together in sharing this one core technology. Together, we 
work on the trade relations and the government issues. 

One of the things that we don't want to see happen with this technology is what took place in the 
German marketplace. In one year, they had over 8,000 drycleaning locations and then the next year they 
had around 4,000. I know we have a speaker from Germany, and perhaps we could ask him why. 
However, the one thing we don't want is to lose half our industry because somebody thinks that there is a 
solution here in technology, and that we need to shake the tree or something. We need to keep our 
businesses active. We have to look for other applications and other ways to expand the business. 

It is important that whatever technology comes out, whether it is the one that Global Tech or 
another is presenting, it has to be low cost. Again, it cannot change the way we do business today. It 
can't have any environmental problems and we have to have a chance to improve. 


82 


Speaking of improvement, these are some of the early results of the Dry Wash chemistry that is 
coming out. Here is a grape juice stain. We have the actual swatches we can pass around. This is a grape 
juice stain that was cleaned with liquid C0 2 using the DryWash process. It worked a little bit on the 

stain. But the moment we added the DryWash fluid, the detergent package, we were able to remove the 
grape juice stain almost completely on wool and on polyesters. 

Why are we doing this? Because when a new technology comes into our marketplace, we have to 
find a way to do business better. We have to have the chance to say, "How can we be more profitable?" 
Our goal with the DryWash system is to eliminate pre-spotting, so that we don't have the labor step there. 

The nice part about using carbon dioxide is that it works in a cool environment, as you will leam 
from the technology council. We clean clothes at 58 degrees Fahrenheit, so you are not setting the stains. 
The DryWash package along with its additives has a better chance to work. 

There is a very good possibility that today we are looking at how to solve the problem with perc 
and tomorrow we can be looking at how to clean clothes in water. This is a laundry standard. This is the 
target that we are looking at. How we could help bring additional business back into the marketplace. 

A lot of people are saying, we heard that you were out here, and we want to have results on where 
you are, where you stand. You have 14 companies sharing technology. Currently, we have machines 
located in: Los Angeles, Minnesota, Wisconsin, Milan, Italy, Sweden, and China. These are locations 
where manufacturers are developing their equipment. They are preparing to release it, and are working 
with their local distribution channels. 

When we do come to market, we will have both a wide span of knowledge base on the process, 
and an understanding of the cost structure involved. Then can they provide the services that we promised, 
while not changing the industry? I can't emphasize that enough. When we commercialize a technology, 
it must address a minimum 70 percent of the industry. When we support a technology in this room or as 
part of this industry, we have to make sure that it is going to expand the business and assist the neighbor 
across the street, as well. 

Whether you are a competitor in a drycleaning environment, whether you are right across the 
street from each other, you need friendly competition. You need to create an environment for providing 
services to the consumer. We have to think together about how to use technology to improve our 
businesses. 

We set up a five-year plan for developing a distribution system for a technology that came out of 
the aerospace industry—somewhere completely outside the drycleaning industry—and we brought it this 
quickly into the industry. Now you will start to see local drycleaners having these DryWash machines, 
and you will be able to see them for yourselves. I think that to do this in five years is pretty astounding. 

I just want to personally think Mary Ellen Weber of the Design for the Environment. It has 
turned out to be a good project from the beginning. Many people are hesitant about talking to 
government officials. However, the leadership that DFE has provided us in giving us an opportunity to 
discuss new technologies and problems has been very special for me. 

So thank you very much for your attention. I truly appreciate your time. 


83 





Results of Pilot Study Comparing New Technology Performance 

Perry Grady, Ph.D. 

College of Textiles, North Carolina State University 

Dr. Perry Grady has taught and conducted extensive research in textiles in instrument and 
control system design and development, energy utilization and conservation, 
electrotechnology applications, fiber production and properties, and garment and textile 
care. He is co-editor of the books Microprocessors and Minicomputers in the Textile 
Industry and Automation in The Textile Industry: From Fibers to Apparel. 


Well, you see you are going to hear from three professors, and you know that professors only 
speak in terms of 50-minute blocks, so this will be an hour and 50-minute speech, I guess. But hopefully 
we'll make it a lot quicker and a lot shorter than that. I think the reason they left me out of the program is, 
they probably discovered that I hadn't done anything. The two guys who are going to talk to you most 
have actually been more intimately involved with the research. 

This is a joint project between the North Carolina State University College of Textiles and Texas 
Women's University, the Department of Fashion and Textiles. I would also like to recognize that this 
work was supported by EPA, the Office of Research and Development, and the project coordinator for 
that is Mr. Chuck Darvin, who is seated over here. He has graciously agreed to answer any nasty 
questions we get. 

Our main purpose in this project is to generate some comparative data on the cleaning ability of 
various technologies that you have heard a lot about. You will see some very specific data on different 
stains, different fibers, and different technologies. These are truly preliminary results that have not really 
been reviewed thoroughly yet. Therefore, we are not planning to give them out as a handout, because we 
won't set input from in these results until later. 

The primary purpose of the project was to develop methods to compare different technologies and 
also work on developing new technologies such as ultrasound cleaning and C0 2 cleaning. 

We are still in the process of developing protocols both for swatches and for garments, and 
therefore we are looking for input. We also have a poster session in the Arlington Room, and we would 
be happy to have you come by and look at even more results than you will see in the paper coming up. 

Dr. Michael Overcash is also going to be involved in this presentation and has done a life cycle 
analysis, and he has a poster session as well. I'm sure he would like to talk to you if you're interested in 
life cycle analysis. 


84 


We are also doing physical tests that will not be covered here; we will be covering just cleaning 
tests, and those are being analyzed and will be presented later in the final report. I also want to recognize 
Mr. Bob McCall, who actually put this presentation together. He was going to be a big part of the 
presentation rather than the three of us, but Bob had surgery yesterday to remove his gall bladder, so he 
was unable to attend today. But he did do a lot of work on this, and I do want to recognize it. 

With that, I'll turn it over to Charles who will start the presentations on the results. 


85 






Results of Pilot Study Comparing New Technology Performance (continued) 

Charles L. Riggs, Ph.D. 

Texas Woman's University 

Dr. Charles Riggs is a tenured professor and Coordinator of the Texas Research Center 
for Laundry and Drycleaning and the Textile Testing Center at Texas Women's 
University, Department of Fashion and Textiles. He is a member of the American 
Association of Textile Chemists and Colorists, American Chemical Society, American 
Oil Chemists Society, and the International Textile and Apparel Association. 


Thank you. It is a real pleasure to be here. One of the things that Manfred did not say in the 
introduction is that I have been involved in the textile cleaning industry for some 24 years. During that 
time, my emphasis has always been quality, that is, the quality of the service. I think it is something that 
hopefully is not being overlooked, but little is being said about it. 

By quality, I am dealing with the question of whether the garment comes back much like it was 
when the customer bought it new. Now, that includes, is it clean? Is it damaged? Has it shrunk? Is it 
finished properly? All of these elements need to be evaluated as we look at the performance of these 
technologies. 

Now, we are going to concentrate primarily on the cleaning aspects. I think you are going to see 
some results that indicate that performance depends a lot on how you do the individual process, whether it 
be drycleaning, wetcleanmg, or whatever system. There are variables within those processes that can give 
you a tremendous range of results. 

When we start to clean garments, we invariably are looking at a compromise. Two of the inputs 
that go into the process are a chemical input and a mechanical input, usually through the agitation or 
rotation in the cylinder. Invariably if we start looking at more and more sensitive garments, we tend to 
reduce the mechanical input and if we don't make up for the loss of mechanical input with chemical input, 
we end up not getting things clean. 

My point is that we should not compromise getting things clean. I don't think that is exclusive of 
our environmental concerns. What I have found throughout the years in working with laundries in the 
drycleaning industry is that the management factors that you have to employ to get good quality tend to 
give you good environmental results. Because you have to manage each detail of the process, the 
equipment also has to work properly, and you have to manage all the inputs and outputs. 

In terms of the overlap of quality and environment, I'd like to borrow a quote from John Michener 
and summarize it. John was at the September '96 conference and has been involved in the industry for 
many, many years. John talked about his recollection of the 1970s of how we began to be concerned for 
environmental topics such as phosphates in detergents. Once the phosphates were taken out it became 
somewhat more difficult to clean things in laundering. 

Shortly thereafter, we had an energy crisis, and we were encouraged to wash in cooler water 
temperatures, and it became more and more difficult to do the chemical process of removing soils. 


86 


Now we are talking about other technologies, and we need to keep this in mind in terms of 
cleaning abilities. John's comment was that to him, his environment began at his underwear. Then the 
cleaning aspects of his environment went from his underwear outward. So I don't think we are 
necessarily excluding one for the other, and I encourage us to keep this in mind. 

In terms of the technologies evaluated, we took on the task of looking at production scale 
machines. These are not laboratory studies so we evaluated production scale machines that were 
currently available to the cleaning industry. The technology involves perchloroethylene and it is well 
defined. I'm going to come back to the definition of perchloroethylene technology again, because as we 
move forward with any of these industries' technologies, we must first define what we mean by that 
technology if we are to use the technology properly. That definition then is backed up by a test method, 
and then garment producers have a test to apply to determine what care label is appropriate. 

At the present time, there is a definition for drycleaning, which in my mind could use some 
refinement. Hopefully, with input from the FTC, we will see some refinement as well as some new 
definitions. 

For example, the definition for the solvent process specifies up to 75 percent relative humidity 
and moisture content. But yet, we see terms that say low moisture and general cycle that aren't defined. 

We also put hydrocarbon solvent cleaning into our system. We opted to use the new generation 
synthetic hydrocarbons, in part because the composition is more precisely known and more reproducible 
results anse from that kind of a system. 

We also looked at machine wetcleaning, which at this point is not a defined term. I think some of 
the deviation we see in results from different demonstration projects comes from the fact that we have not 
defined what we meant by wetcleaning. 

Ken Adamson is the only one that showed details of the process. He showed processes ranging 
from a machine turning at five RPMs, a very gentle cycle, to one turning at 28 RPMs, a much more 
aggressive process. How you do the test determines how much damage or how well this process cleans. 

For this test, we used the machine operating guidelines that are being proposed by the Europeans 
in their round-robin testing of wetcleaning machines and wetcleaning systems. It is the definition that we 
will propose to the AATCC as a definition for what wetcleaning consists of. In the protocol we are 
following, we will set forward and encourage them to adopt a certain standard. The standard would tell a 
manufacturer if they could wetclean something using this process based on a wetcleaning label or if it 
needed to have one of the other labels attached. 

In looking at the evaluation, we used the IWS wool test fabric. This is a fabric that is commonly 
used in Europe. It is actually part of a test for compliance of home machines for home use in Europe, but 
it is also a reasonable fabric to look at in terms of potential for damage in these technologies. The fabric 
will shrink if it is not handled properly. 

We also looked at the standard testing device used widely in the cleaning industry. The device 
was produced by IFI, which includes some water soluble and some soils required to be removed by 
mechanical action. We also looked at some standard soil materials from WFK in Europe. We actually 


87 



tended to drift towards the WFK material as our preferred one. It is a composite of 16 different soils, that 
is, 16 different combinations of soil and fabric. 

Here is a slide which summarizes the shrinkage data for one cycle and eight cycle cleaning, 
wetcleaning, hydrocarbon cleaning, and perc cleaning. Not too surprising, we see more shrinkage with 
wet cleaning because of the nature of the wool fiber on exposure to moisture. 

Looking at the soil removal, we see the soil properties depend on what kind of soil we have. The 
dye stain on the EFI soil test swatch is a water soluble dye. It comes out very nicely in wetcleaning. How 
well it does in solvents depends primarily upon the detergent additive. 

In this particular case, the detergent that we used with the perc turned out not to be a very good 
one. In fact, with the other detergents, we would see the perc and hydrocarbon results look more similar. 
But it depends very much upon what detergent system you use. 

The WFK fabrics consisted of combinations of polyester with pigment and sigma soil. Sigma soil 
is a simulation of colored soil, and the pigment is something that requires some mechanical action to 
remove. The slide shows silk fabric with same soil; wool with an olive oil; and wool with a pigment and 
sigma soil stains. 

This particular choice of fabrics probably did not give wetcleaning a fair shake, because these 
fabrics primarily have soils that are more suitable to a non-polar solvent such as perc or hydrocarbon. 
Indeed, the results are much as you would expect, which means if we were trying to wetclean these soils 
in these fabrics, to do it successfully we need a better detergent system than the one that was used. 

There are 16 soils. I won't read the list, but let me just point out that what we have with these 16 
is a very good combination of soils that are removed by polar materials and non-polar materials, that is, 
solvents versus water. So this seemed to be a good selection of soils and fabrics that would give all the 
technologies a relatively fair shake in the evaluation. 

Here are the results. I call this slide the skyline of New York City. The peaks and valleys depend 
very much upon which soil and which cleaning system. You can see the cleaning systems as we go 
across the far chart and the one in the front is perchloroethylene with a detergent. Then we have three 
wetcleaning systems with three different detergents and three hydrocarbon systems with three different 
detergents. 

Now, I won't show you every single set. You can see those in the next room in the poster session, 
but let me look at a couple at random. This is a sigma soil. This is a soil that is a non-polar soil. It is best 
suited to solvent systems and we see that wetcleaning does not do as well as the others. 

However, we are now looking at a soil that is more suitable to a water based system. Indeed, the 
wetcleaning process does better than the soap color systems with blood, milk and ink on cotton. 

Now, how do you address this in practice? If you are using this kind of a cleaning system where 
you are trying to remove a polar soil with non-polar solvents, you have to add moisture and detergent to 
the system. On the previous slide we had a water based soil that did very, very well after wetcleaning. 


88 


In this slide, we have the reverse, a non-polar soil that is best removed by solvent. In this 
process, the wetcleaning system again would need some kind of an additive to better address the removal 
of the soils, or more mechanical action. However, if you increase the mechanical action, you also 
increase the potential for fabric damage. So at what point can you still clean and not damage the fabrics? 

In the poster session, you will see additional data, additional results, and a view of actual cleaned 
samples. Our future plans would call for us to continue with the fabric damage aspects of this research. 
Other cleaning technologies would hopefully include a carbon dioxide system, (if we can convince them 
to put the machines in the plant), and a system using the glycol ethers that are primarily promoted by 
Rynex. 


The poster session will look at the various cleaning processes and the dimensional performance of 
actual garments. Concerning the bottom line, I advise you, the cleaner, to match the cleaning system with 
the soil and the fabric. Based on the data we are seeing, there is not a single universal system that works 
for everything. The best solution is something like what Ed Boorstein is doing. He takes in the garments 
and has technologies both wet based and solvent based. He then uses his personnel's knowledge to select 
the right system for the right soil and the right fabric. 

The additional data is presented by Gary Mock on an emerging technology. 


89 



Results of Pilot Study Comparing New Technology Performance (continued) 


Gary Mock, Ph.D. 

North Carolina State University, College of Textiles 

Gary Mock is a professor at North Carolina State University in the Department of Textile 
Engineering, Chemistry and Science. He has held many professional positions in the 
textile industry, including Development Engineer and Quality Control Manager at 
Milliken & Company. 


Thank you, Charles. I see that I have already used up all the time available to us, thanks to a 
tardy start. 

For several years, we at NC State have been a team looking at alternative technologies and the 
possibility of using ultrasound as a means of improving dye penetration; or of improving dye washoff 
after dyeing to get rid of unfixed dyes. Results were very promising and showed that we could lower the 
temperature or shorten the time that was needed for these operations. We also used less chemicals, in 
particular salt as an additive for dyeing. 

When EPA decided to examine alternative cleaning systems, we proposed a senes of studies to assess 
the replacement of oxygenated solvents with perchloroethylene, and to use ultrasound to provide the 
thermomechanical energy needed to help loosen soil. 

I'd like to talk to you about the three methods studied. We took a look at tumble drying, using 
100 percent perchloroethylene as a standard. This was done several years ago, where we used a 
launderometer as the sample test method in the laboratory. We then proposed using ultrasound as the 
alternative to that, where we would use 100 percent solvent, and we would either put it in 
perchloroethylene or several of the oxygenated solvents that I will mention shortly. 

What we looked at was ultrasound wetcleanmg, where we would use about six percent solvent 
instead of 100 percent solvent. The solvents that we chose to use were n-methylproladone or NMP, 
propylene glycol tertiary butylether, or PTB, and PNB, or propylene glycol n-butyl ether. These were 
selected after going through an extensive screening to look at a number of potential solvents that would fit 
a number of factors that we wanted to look at such as flash point and so on. 

The one that we finally decided on was water, solvent and detergent. The solvents used were the 
ones that I just mentioned: NMP, PTB and PNB. 

The fabrics that we chose were chosen from local stores where we could go in and purchase 
samples of wool, silk, rayon and acrylic typically used by a typical home craftsman. We did this just to 
see what was available on the market. This was before we got into standard samples that were available 
from standard sources. 

The soils that we chose initially were ones that we thought would be particularly difficult to 
remove. So we decided we would use motor oil, that would typically get on peoples' clothing if they were 
changing oil in their car. We thought about ballpoint ink and finally settled on using a stamp pad of ink. 


90 


We also used lipstick as another type of soil that could somehow make its way onto clothing. I don't 
know how that happens, but it does happen. 

Some of the results that we show are looking at a gray scale, an AATCC gray scale, were five is a 
perfect result. Results show that not surprisingly, engine oil is very well removed by perchloroethylene. If we 
looked at ultrasound added cleaning, we see various results. All technologies remove lipstick quite well. 

Incidentally, the temperature that we used here was about 50 degrees C, corresponding to about 
120 degrees Fahrenheit. 

Looking at silk fabric, again we see that engine oil can be removed by a number of different 
processes. However, none of the processes remove ink very well and lipstick is removed better with a 
wetcleaning than with a perchloroethylene cleaning. 

Rayon fabric, is cleaned with different results with the different technologies. I think this backs 
up what Charles said. You have to know what kind of soils you have, what kind of fabrics you have, and 
choose the optimum one. You almost need an expert system and experience is an excellent guide to 
choose what you want. 

Lastly, the slides show acrylic fabric, with these results. You can see all these results detailed in 
our poster session. 

One other thing that we thought we needed to ask was, "what happens to the fabric after we have 
cleaned it?" It is not sufficient just to clean something if you have thoroughly destroyed the system. At 
our College of Textiles, we happen to have access to a Kawabata surface roughness evaluation system 
that literally was developed using a mechanical fingering system that moves across the surface of the 
fabric to determine the relative roughness of the fabrics. 

Here we see a series of results that we can look at: how perchloroethylene works with the various 
samples. We have a grouping across the bottom, ultrasound for 18 minutes, then ultrasound for 30 minutes. We 
have groupings of the three oxygenated solvents, but we couldn't get into the Power Point presentation. 

The conclusions from all of this work, which is very, very condensed, is that we feel that 
ultrasound aqueous based cleaning has a very good potential for removing hydrophobic soils that are 
normally removed only by drycleaning. The cleaning times were also significantly shorter using 
ultrasound. 

What we haven't talked about, but was another part of the study, was that no shrinkage was seen 
for wool samples or silk. Based on these results, it seems ultrasound is a really good technology to 
consider. 


91 




What we want to work on in the future is to continue to look at ultrasonic cleaning, and how it 
works with standard soils, and aqueous solutions. We will also perform some additional testing on some 
new equipment that we have acquired from a company that makes a near-field processor, Advanced 
Sonics of Connecticut. We would like then to move on to testing how ultrasound can clean small 
garments. 

Thank you very much. 


92 


Textile Care with Glycol Ethers 


Stephen P. Bates, Ph.D. 
Rynex Holdings, Ltd. 


Dr. Stephen P. Bates is currently an assistant professor of environmental technology at 
New York Institute of Technology. He is a certified professional chemist, professional 
environmental auditor, certified environmental trainer, and registered hazardous 
substance professional and certified environmental inspector. 


Thank you, Manfred. It is a pleasure to be here. Good afternoon. I'd like to thank you for 
inviting me to the EPA Design for the Environment conference. I am pleased to be here on behalf of 
Rynex, which is a breakthrough product in scientific technology. 

Rynex is participating in the U.S. EPA Design for the Environment Garment and Textile Care 
Program, because we are excited about this product, and because we believe that this program is vitally 
important for our industry. Rynex also believes that we really do need sound unbiased science, and that it 
is critical in the decision making. 

As an environmental chemist, I'm concerned about our future. My background is really involved 
in testing and looking for toxic and hazardous materials. After getting involved in this program, we really 
had to look to see where we were going with this. We didn't want to start working with materials that 
were going to end up biting us in the back later on. 

As we approach the next millennium, we are reminded of our past problems in this industry and 
the promise for the future. We owe it to our children to bring forward new technologies that are 
environmentally friendly and will minimize the impact on our environment. The drycleaning industry is 
going through a tough time, and trying to make decisions on alternative technologies today is very 
difficult. 

My goal today is to present to you Rynex, an alternative technology. One thing I want to point 
out, Rynex is a clean, modem, organic chemistry. It is designed specifically for the drycleaners. This 
program arose in response to finding alternative technologies using conventional drycleaning equipment. 
We didn't want to have to re-invent the wheel. After all, there is so much equipment out there already. 

We needed to make sure that we look to protect our atmosphere, our biosphere, and the environment in 
general. 


The Rynex product is designed to bring less stress and more cleaning into fabrics. This is a 
unique technology. The United States Patent and Trademark Office has accepted our patent claims, and 
as we speak, our patent attorneys are working on worldwide patent claims. 

Some of the benefits and features of this product are that we have 30 to 50 percent greater solvent 
efficiency than perc. We are actually getting garments cleaned better than perc. Our whites are whiter, 
the garments don't turn gray, there are less chemical byproducts, we are earth friendly, human friendly 


93 




and atmosphere friendly. Another great point that we need to make, is that we have enhanced optical 
brightness in the garments. 

The chemistry here is important, too. Rynex is an oxygenated solvent. It is a P series glycol 
ether. Presently this is a proprietary formula, primarily because we are going through patent claim issues, 
and we have to make sure that the intellectual property is protected. 

But one thing that is important to note is that we have the ability to carry water along with our 
solvent system. The molecules are able to form an azeotropic mixture. 

The other important thing to note is that this is really more than just a solvent. We have a 
surfactant that we are working with here. The molecules that we are working with have both polar and 
non-polar sides to them, where they become hydrophobic and hydrophilic, so it does act as a surfactant. 
This enables extraordinary cleaning properties. 

When we are looking at trying to come up with alternative technologies, we really have to look at 
a large number of properties in solvent systems in order to come up with the various drycleaning 
requirements. As you can possibly imagine, there are many items that have to be dealt with. 

Rynex is able to clean so well by the nature of our formulation. We have both the sufficient 
solvency to break down solvent soluble fatty acids, and the ability to carry sufficient moisture and water 
to break down the water soluble stains. The beauty of this process is that we can take care of both 
problems simultaneously. 

Another requirement that we have is that the solvent must be removable from the garments at 
relatively low temperatures. You can't overheat these garments, or else you will end up with shrinkage 
and all kinds of other problems that could occur from overheating. 

Another requirement is that the material has to be filterable, so you can remove some of these 
soluble and non-soluble materials. And you have to be able to distill it and refilter it or recycle it. We 
need to be able to recycle these materials. It is very important that we get to get the most usage out of 
whatever resource we're going to use in this process. The more we can reuse the same resource over and 
over again, the better off we are. 

Another drycleaning requirement is that you've got to assume that the fabric that you're cleaning 
is going to be there when you're finished. A lot of problems arose when we tried different solvents in the 
past, and one of the jokes was that we clean a jacket and people would say, "I hear you're having 
problems with acetates, and we would say no, we're not having problems with acetates; we just can't find 
them when we're finished." 

So we have learned from our mistakes. There are plenty of problems, trying to find the right 
formulation, and certainly we have to deal with buttons and sequins and dyes, and trying to figure out the 
best alternatives and to balance all of these things. It is quite a task. 

Another procedure we have to deal with is separating the solvent system from the water. We 
carry water, but we don't want to carry excess water. We have to be able to reject water. In that regard 
we're very good, because we can get a clear demarcation between the Rynex solvent and excess water. 

As you all know, excess water causes shrinkage, so we have to be very careful. 


94 


Some people ask, "Why do you use an azeotropic solvent?" And what is an azeotropic solvent? 
Well, this isn't new technology. We have been using azeotropic solvents for a very long time. But what 
we have here truly is a major breakthrough with the azeotropic solvent system, because our solvent acts as 
a surfactant. This combined with the water helps to remove and suspend the soils in the solution. We can 
then take the soils out and reject them, and there is no repositioning of the soils into the textiles. This is 
very important. 

Another important attribute of working with water and a propylene glycol ether system is that it 
has the ability to act like a single substance. This occurs because the water combines through various 
molecular forces, that is, hydrogen bonding, and different dipole induced effects, where the water actually 
attracts to the molecule and stays with it, in such a way that we can deal with the water soluble side of the 
problem as well as the oil and fatty acid side of the problem. This allows us to avoid any soil 
redepositioning. We can reject water and take only what we need. We have a low level admissibility, 
meaning that we can take in a certain amount of water and then reject whatever excess water is there. 

There have been a lot of questions about safety regarding glycol ethers, and not all glycol ethers 
are created equally. There are good glycol ethers and there are bad glycol ethers. Rynex is a good glycol 
ether because it is a propylene based glycol ethers. There have been numerous studies done including 
laboratory animal studies conducted by Arco Chemical, who is the supplier of the material. These studies 
have concluded that propylene based glycol ethers don't produce the same types of toxicological effects 
that are associated with the ethylene based glycol ethers, such as the neurological system issues, as well 
as the developmental toxicity problems. 

We have to look at the environmental sides of it as well. The propylene glycol ethers are 
environmentally friendly compounds, and they are inherently biodegradable. 

Performance criteria is another very important issue when we are looking at drycleaning. In our 
testing and pilot testing, we found that we were 100 percent effective at cleaning 99 percent of the 
garments, and that we are removing the water soluble stains and the oil soluble stains. Rynex is also very 
good with removing animal protein, and it doesn't shrink wool. 

The one area of problems that we are seeing—which seems to be prevalent throughout the 
industry—is dealing with acetates and poorly bonded dyes. We are working hard to try to solve those 
problems. 

Another issue is economics. There is no sense in developing a system that no one can afford. 

One of our goals is to try to use conventional technologies by just having a replacement solvent system. 

When you look at the entire big picture, Rynex is cost effective to use because we are getting 
much greater solvent mileage and we're not producing hazardous wastes. There is far less chemistry 
required for the cleaning process, unless spotting agents are being used. 

Our cycle times are overall approximately equal to perc on closed circuit dry to dry machines. 

We continue t<? do research in this regard. Rynex has our own applications laboratory, where we have 
drycleaning machines, and we are constantly testing different things. We are also working quite closely 


95 



with Arco Chemical in tweaking the formula. We are looking at removing certain isomers and other 
similar procedures. 

I am also pleased to announce that our relationship with TNO Netherlands has resulted in the 
installation of a machine there. TNO Netherlands is an independent research laboratory supported by 
major research laboratories and manufacturers, and they have been able to secure one million dollars in 
funding to thoroughly test this product. They will be performing 60 different tests on Rynex, and we are 
very excited about that working relationship. 

In summary, we are very proud that this is a scientific breakthrough in cleaning technology, and 
that we are an environmentally friendly solvent specifically dedicated for the drycleaning industry. 

I'd like to thank you for taking the time to listen, and also to offer people who are working in the 
drycleaning industry a drycleaner information packet which I could mail to anyone. We have a poster 
session outside, and some forms where you could ask for additional information. If you would be so kind 
as to leave a card or whatever, please do so or stop me and talk. I'd love to talk to you and tell you all 
about Rynex. 

Thank you very much. 


96 


Rynex Corporation www.rynex.com 
(516) 364-8993 


Rynex 

U.S EPA Design for the Environment 
Garment and Textile Care Program 

i- " 

l 

Stephen P. Bates. Ph.D. 

Rynex - A Scientific Breakthrough in Cleaning 
Technology using Earth Friendly Chemistry 


Overview> 


• Rvnex is clean modem organic chemistry 
designed specifically for the drycleaners. 
the environment the atmosphere and the 
biosphere 

• Rynex is designed to bring less stress and 
more cleaning into fabrics. 

• USPTO has accepted patent cl aims 

• Unique formulation (P- Series Glycol ether) 





Features & Benefits 

Chemistry 



• 30 to 50 % greater solvent efficiency than 

Perc (1250 lbs. /gal. vs. 850 lbs./ gal.) 

• Better cleaning than Perc (whites are 
whiter). 

• Garments don't turn gray. 

• Less chemical by-products. 

• Earth friendly, human friendly, atmosphere 
friendly. 

Rynex is a proprietary IT- ^ - The base molecule 

formula!!on using a - -_J - - '5-'- is not only a solvent 

Propylene glycol ether. but a surfactant as 

We are able to carry ® well One end of the 

some water molecules x molecule is 

through hydrogen Ch 2 hydrophilic and the 

bonding and other other is lipophilic, 

molecular attractive CHOH enables 

forces forming an / extraordinary 

azeotropic mixture cleaning properties. 





[ Dry Cleaning Requirements 


• A drycleaning solvent requires the 
following characteristics: 

• Sufficient solvency to break down solvent 
soluble fatty acids. 

• The ability to carry sufficient moisture 
/water to break down water soluble stains. 


Dry Cleaning Requirements 


• The solvent must be removable from the 
garments at relatively low temperatures 
during the drying process. 

• Filterable to remove non-soluble particulate 
matter. 

• Be able to be distilled to remove soil, fatty 
acids, dyes and any additives and reclaim as 
a pure solvent. 



























































Rynex Corporation www.rynex.com 
( 516 ) 364-8993 




Dry Cleaning Requirements 


• Must not cause any damage to the broad 
spectrum of natural and man made fibers or 
the accessories (buttons, sequins, dyes etc.) 
used in modem garments. 

• The solvent must be able to separate from 
excess/free water. 

• The solvent must remain stable in the 
presence of other chemicals and after 
repeated distillations. 




Why Use an Azeotropic Solvent 9 


• The Rynex solvent is an azeotropic mixture 
of water and a propylene glycol ether 

• This safe solvent system has the advantage 
of behaving like a single substance. 

• A mixture of chemicals is azeotropic if the 
vapor composition is identical to that of the 
liquid phase. 

• The dry clean mg process requires water to 

— remove water s o l uble stain s -, 


Why Use an Azeotropic Solvent? 

• Soil suspension capabilities to reduce 
redeposition. 

• A solvent for textile cleaning must be able 
to carry water but reject excess water. 

• Rynex has a low level of miscibility and 
free water is easily separated out 

• Excess free water may cause shrinkage. 


Safety 


• P-Senes Glycol ethers are inherently safe. 

• Based on laboratory animal studies, 
propylene glycol ethers do not cause the 
type of toxicological effects that are 
associated with exposure to ethylene glycol 
ethers. 





l Environmental 


Performance Criteria 




• Propylene glycol ethers are environmentally 
friendly. 

* Studies indicate that the material is 
inherently biodegradable in 35 days. 


• 100% effective cleaning on 99% of the 
garments. 

• Removes water soluble stains. 

• Removes solvent soluble stains.(i.e. oils and 
fatty acids.) 

• Removes animal protein stains. 

• No shrinkage of wool. 

• Poorly bonded dyes may bleed. 

































































Rynex Corporation www jynfix.coin 
( 516 ) 364-8993 







Economics 


| Machine Cycle Times 





• Cost effective to use. 

• 30 to 50% greater solvent mileage 

• Far less chemistry required for the cleaning 
process. 

• Less spotting agents being used. 


• Overall cycle time approximately equal to 

Perc on closed cycle to dry to dry machines 







Research & Development 


• Rynex Research Laboratory 

• ARCO Research Laboratory 

• TNO Netherlands Independent Research 
Laboratory supported by other major 
laboratories and manufactures. 





























C0 2 Process Testing Results 


Craig M.V. Taylor, Ph.D. 

Los Alamos National Laboratoiy 


I'm Craig Taylor from Los Alamos National Laboratory. I'm in the chemical sciences and 
technology division. The technology that we have been working with was an R&D 100 award winner. 

This next slide here gives you an idea of the different areas that we work in as far as supercritical 
fluids and dense based fluids. We work all the way from supercritical C0 2 , which goes into fabric 
synthesis, dye impregnation, et cetera, all the way over to the supercritical water. Supercritical C0 2 tends 
to make things and supercritical water tends to destroy them, so we work the gamut there. 

LANL's role in this project was originally with LANL and Hughes Environmental Systems, who 
has now become Creda, which was partially funded by DOE and EPA to develop this alternative solvent. 

Liquid C0 2 is based on a weapons technology that was essentially made so that you could clean 
parts and not leave any residue on the parts. Zero residue technology was the idea behind all of this. It 
moved into nuclear laundry, because there you have a lot of problem with any solvent, including water 
and the discharge. 

This is just a quick slide to show you some attributes of C0 2 . It starts out as a gas, then it is 
liquefied under pressure. Once in liquid form, C0 2 has these great properties—non-carcinogenic, 
non-mutagenic, non-toxic, non-flammable, non-ozone depleting, and it is basically non- everything, very 
good for the environment. 

C0 2 naturally occurs. There is a carbon cycle at work in the world which is very efficient at 
removing it then from nature. I think a lot of people have been putting this up, but just to give you an 
idea, this slide shows the solvent properties of C0 2 versus perc, petroleum and water. The ones in black 
are the ones we're going to stress and point out. 

The first black item is density. The density of C0 2 is adjustable all over the board, but in the 
liquid region it generally tends to be between 0.6 and .9. Density is important because the solvent 
property of any given solvent varies as a function of its density. 

Surface tension is a measure basically of how well a material can wet a surface. If the surface 
tension is high, i.e., water, then it requires the use of surfactants in order to allow and enhance the waters' 
ability to wet the surface and cause effective cleaning. The supercritical, or liquid, carbon dioxide in this 
case, you can see, has a very low surface tension, supercritical having a zero surface tension. This means 
that it is very good at wetting material so that it can clean it. 

Then last, but not least, is the viscosity. The viscosity for the liquid is very, very low. This 
factors in when you're looking at power requirements to pump it, and also for how it is going to affect 
clothes when you use mechanical agitation. 


97 


The main goal of the entire technology is to get a product that cannot only be recommended, but 
whose use is beneficial. 

What we entered into was a system where we were using perchloroethylene as a baseline, much 
like everybody else that you have seen today. We were going to compare our technology to the 
perchloroethylene, which is the industry standard right now. 

The first item we looked at is the operating parameters. Liquid C0 2 operates at 700 to 750 psi, 54 
to 58 degrees Fahrenheit. It uses a hydrodynamic agitation, which means that it is actually the liquid that 
is moving, not the drum. We tried to keep down the number of moving parts so that we don't have to 
worry about having seals fail under pressure and affecting the lifetime of the machine. 

The solvent was liquid C0 2 . It says plus additives, but what I am going to go through today, just 
to keep everyone on an even keel, is just straight C0 2 numbers. So everything I go through today, 
remember, is just straight C0 2 . There are no additives used, because as we all know, there are at least 
three different companies that have been presenting today that have different additive packages and 
different machines. So we're just dealing with C0 2 with this kind of an agitation system. 

This is a list of the textiles that were evaluated. Trims were also evaluated, as well as leather, furs, 
buttons, zippers, decorations, et cetera. 

I just want to show you this slide real quick to give you an idea of how this works. Remember, 
we're at 700 to 750 psi. You can see that means that essentially we are operating at lower pressures than 
the soda fountains in the drugstores. That is an important thing to remember, that we are in a range that 
people are very used to handling, and it is also very important to note that we are in a range that actually 
is about where the liquid C0 2 gets delivered. 

Here is an evaluation category that compares C0 2 performance to perchloroethylene. These 
studies are done in a very similar fashion to Dr. Riggs' studies. We have actually collaborated with him 
on many of these. IFI supplied most of the materials that we were actually testing. Most of the materials 
we first tested were swatches. We found that because of the mechanical agitation that is necessary to 
cause effective cleaning, you needed to take the swatch and actually pin it on to the inside of a garment. 
This gives you enough length in the garment to go ahead and cause the stretching and compression, which 
causes the dirt to separate from the garment. 

Again, you can see that in all cases and for all of these swatches, the cleaning was essentially 
equivalent or better than perchloroethylene. 

I've got to tell you a story before I put this next slide up. When I was growing up, my mother 
drove a school bus. She got home before everybody else did. She got home one night and our dog, 
which was a boxer at the time, was sitting there just proud and happy, and had a dead rabbit in its mouth. 
Well, our neighbors raised prize floppy-eared rabbits, so she had been told a lot of times that if this dog 
came over and killed one of the rabbits she was going to be in real trouble. 

After finding the dead rabbit she panicked. She took the rabbit and she ran into the house and she 
got it in the shower and shampooed it, cleaned all the dirt off, and she got a hair drier and dried it, and it 
looked just right. She snuck over into the neighbor's yard and she put it into the cage, and she tiptoed 
back, and she raked leaves for a little while. 


98 






The lady came home and she went back out the cages and she heard this blood-curdling scream. 
She ran over there to find out what was happening, and the lady told her, "Oh my God, it's Fluffy. He 
died and I buned him three days ago, and now he's back." 

The reason I told this story is because when I put this slide up, I want to say that things aren't 
always as they seem. This shows a comparison of soluble soil removal for the IFI cleaning with soap and 
water, C0 2 , perchloroethylene with additives and in perchloroethylene without any additives. 

Remember that C0 2 has no additives in this example. The C0 2 did outperform the 
perchloroethylene with additives. However, the perchloroethylene without additives went negative. This 
is because we are actually using the gray scale testing and what happened was that perchloroethylene 
without additives was actually redepositing on the surface. 

This next slide shows the shrinkage after liquid C0 2 exposures. We did these tests at zero percent 
humidity, 70 percent humidity and 100 percent humidity. You can see the list of matenals that we did the 
tests on. You can see that C0 2 didn't perform very well on dye acetates in almost all cases. However, 
only for the zero percent humidity case are we actually outside the industry standard, which is around two 
percent, usually. 

This slide is a very interesting thing because it isn't exactly what it appears. The dye acetate also 
causes a problem in the perchloroethylene, though, and therefore they are actually fairly comparable. But 
performance wise, this is where there is a problem for just straight C0 2 . 

This slide shows the average percent weight change for all fabrics. Again, zero to 100 percent 
humidity. You can see that immediately after exposure, and then two to four days, and after ten 
exposures, that there is a weight difference. This difference is in percent, and in most cases we don't have 
very much trouble. However, you do see as you begin to build up pressure and humidity, a problem 
which people have mentioned before, which is a formation of the carbonic acid. This can be taken care of 
very easily usmg a buffer in the surfactants that are actually used. 

These are the advantages of the C0 2 . Number one, I think we have shown that it cleans well. 
There is no heat setting of stains. This is basically because the temperature never gets above 56 degrees 
Fahrenheit, so it is relatively cool all the time. 

Also, C0 2 cleans everything and is safe to use on most dyes. The reason we say most dyes is 
that we haven't tested all dyes. However, I can tell you that at the temperatures and pressures at which we 
are running, thus far we have not found any dyes that cause any problems. 

Another benefit of C0 2 is that there is no residual solvent in the waste. This is true if you are 
running plain C0 2 . However, it can change when everyone starts examining what kind of surfactants they 
are going to add to the C0 2 . That is, if you add surfactants, the C0 2 is going to go away very easily, but 
you're going to be left with the surfactant and the dirt that you have to dispose of. 

There is no health problem with C0 2 . A lot of people have asked questions about what happens 
if this thing goes off and fills the room full of carbon dioxide. There are a couple of things to remember. 
One, if you have a dramatic release of carbon dioxide, it is going to turn into dry ice and bleed off 


99 


gradually. You're not going to fill a room with carbon dioxide unless you have an insidious release, i.e., a 
leak, and that is fairly easy to handle. Most of these machines will have to have some sort of detector 
sitting next to them to determine the C0 2 levels. 

There are also no hazardous waste costs and no environmental problems associated with C0 2 . 

Basically what I'm going to do here with the last couple of slides is just give you an idea of how 
the machine works. It basically uses jets that are introduced tangentially into the cylinder itself. This 
causes the fluid itself to move, pick up the clothes, and move the clothes around. Some of these jets move 
in one direction and some move in another so that you can switch direction and get the agitation motion 
that you need. 

This slide shows a blocked diagram of the process. As you can see, this process does not have 
any kind of separator. What you have is a storage vessel. It has an offline still which will repurify the 
C0 2 . It goes through pumps and a series of filters, and then back into your vessel. 

Basically, this is a very simple system. It has been kept that way for a reason. Also, the drying 
does go on within the same vessel, meaning that when you take these garments out, they are already dry, 
they are a little bit cool, and they aren't very wrinkled. It is a very high performance machine. 

The cycle time for the process is usually about half. It is usually about 20 to 25 minutes for the 
entire cycle and again, it is coming out dry at the end of that cycle. 

This is the conclusion of the talk. I think that most of the data that I have presented is available in 
the handout that everybody should have. Anything that is not there that you would require, I welcome 
you to contact me and get copies of the slides, or you can also get onto our website, which is 
www.scrub.lanl.gov. 

Thank you very much. 


100 











iwntapc. 


friendly Solvent* 

* - - .'T .*'■ 9 

; : ’ Generates no 

hazardous wastes 

•, ; or emissions 

• * 

• ■ ?. ** * 

f 

>♦ • 

Cuts dry-cleaning 
timeby 50% 

* • . r : ■ - . • 

♦ • br « r. 

Adduces energy 
consumption and 
* * ’ labor costs 


mmMMzmm' 

| 




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1997 R&D 100 Joint Entry 


DryWash™ 

Los Alamos National Laboratory, 
Global Technologies, LLC, and 
Hughes Environmental Systems, Inc. 


ABOUT THE COVER: 

The red food stain shown in the background photograph might send 
anyone scurrying to a dry cleaner. But rather than cleaning this 
polyester swatch in perchloroethylene (perc), the hazardous solvent 
that dry cleaners typically use, we have removed the stain with 
dense-phase carbon dioxide (CO,). The stain is greatly reduced 
partway through the cleaning simulation (left inset) and is 
completely gone by the end (right inset). Our DryWash™ process, 
which agitates and cleans garments with high-speed jets of liquid 
CO,, offers an effective, environmentally friendly alternative to perc. 

Los Alamos 

NATIONAL LABORATORY 


Executive Summary 


DryWash™ 


Features 


Applications 


Benefits 


DryWash™ is a fast, nontoxic dry-cleaning process based on liquid 
carbon dioxide (COJ that is applied through high-speed fluid jets. 
Liquid C0 2 is an odorless, nonflammable, nonhazardous solvent 
that effectively removes oils, sweat, and dirt from a wide variety 
of fabrics. Both efficient and environmentally friendly, DryWash 
is the needed replacement for the hazardous dry-cleaning methods 
currently used. 


DryWash cleans most linens, throw rugs, and everyday or fine 
garments—even furs, leathers, suedes, and items with sequins. 
It can be used worldwide by retail dry cleaners, hotels, military 
installations, corporate facilities, nursing homes, and hospitals. 
Future applications include dishwashing and decontaminating 
machined parts. Eventually, small-scale versions of DryWash 
may be used in homes for cleaning laundry and dishes. 


• Uses a nonflammable, nontoxic, inexhaustible solvent. 

• Does not deplete the ozone or pollute the ground water. 

• Helps the dry-cleaning industry comply with federal and state 
environmental regulations because the process minimizes 
hazardous wastes and emissions. 

• Cleans in half the time required for conventional dry-cleaning 
processes. 

• Reduces dry-cleaning costs by lowering energy consumption, 
run times, and labor costs. 

• Reduces soil redeposition on fabrics, or graying, leaving laundered 
garments bright and clean. 


1997 R&D 100 Joint Entry 


Page I 


DrvWash™ 




1997 R&D 100 Award 
Joint Entry Form 

1. Submitting organization 


2. Joint submitter(s) 


3. Product name 



Organization Los Alamos National Laboratory 
Address Mail Stop E537 
City, State, ZIP Los Alamos, NM 87545 
Country USA 
Submitter Craig M.V. Taylor 
Phone (505) 665-3545 
Fax (505)667-6561 

AFFIRMATION: I affirm that all information submitted as a part of, 
or supplemental to, this entry is a fair and accurate representation of 
this product. 


(Signature). 


L 




/ 



Organization 

Hughes Environmental Systems, Inc 

Address 

Box 902, Building E4 

Mail Stop P103 

City, State, ZIP 

El Segundo, CA 90245 

Country 

USA 

Submitter 

Sidney C. Chao 

Phone 

(310)616-4017 

Fax 

(310)616-0494 

Organization 

Global Technologies, LLC 

Address 

222 North Sepulveda Boulevard 
Suite 2200 

City, State, ZIP 

El Segundo, CA 90245 

Country 

USA 

Submitter 

Jack R. Belluscio 

Phone 

(310)414-9680 

Fax 

(310)414-9682 


DryWash™ 


1997 R&D 100 Joint Entry 


Page 2 


DrvWasli™ 










4. Brief product description 


5. Eligibility: When was this 
product first marketed or 
available for order? 

6. Principal developer 


7. Product price 


8A. Do you hold any patents on 
this product? 


DryWash is an efficient, nontoxic dry-cleaning process that uses 
liquid carbon dioxide (C0 2 ) as the cleaning solvent. The DryWash 
machine consists of a stationary cleaning vessel, CO, storage and 
distillation tanks, and a recirculation loop. Inside the cleaning vessel, 
high-speed jets of liquid C0 2 soak and agitate the garments. 


DryWash is a Trademark of Hughes Aircraft Company. 


Month July 
Year 1996 


Name 

Position 

Organization 

Phone 

Fax 


Craig M.V. Taylor 

Technical Staff Member 

Los Alamos National Laboratory 

(505) 665-3545 

(505) 667-6561 


Begin Proprietary Information 

$60,000-$80,000 per 10,000-pound machine with a capacity of 
22 pounds (assuming one garment per pound). 

End Proprietary Information 


YES 

Hughes Aircraft Company holds the following patents: 

“Cleaning by Cavitation in Liquefied Gas,” US Patent 
No. 5,316,591, May 31, 1994 

“Low Cost Equipment for Cleaning Using Liquefiable Gases,” 

US Patent No. 5,339,844, August 23, 1994 

“Method Using Megasonic Energy in Liquefied Gases,” US Patent 
No. 5,456,759, October 10, 1995 

“Dry Cleaning of Garments Using Liquid Carbon Dioxide under 
Agitation as Cleaning Medium,” US Patent No. 5,467,492, 
November 1995 


1997 R&D 100 Joint Entry 


Page 3 


DrvWash™ 




8B. Do you have any patents 
pending ? 


YES 


8C. Do others hold patents on 
this product or a similar 
product line? 

9. Primary function 




NO 


The dry-cleaning industry is seeking a replacement for 
perchloroethylene (perc), the toxic organic solvent currently used 
by 90% of all dry cleaners. Our DryWash process, which cleans 
with liquid C0 2 , offers the most effective yet environmentally 
friendly alternative that has been developed (see “Carbon Dioxide 
as an Environmentally Conscious Drycleaning Solvent” in the 
Appendix). Carbon dioxide, either in its liquid or its supercritical 
state, has been used in the past to clean a variety of electronic, 
mechanical, and optical equipment, but DryWash is the first process 
that uses CO, as a cleaning solvent for fabrics. The DryWash process 
can be used for most fabrics that dry cleaners commonly encounter 
and can also safely clean furs, leather, sequins, and other sensitive 
items (see “Fabric Compatibility and Cleaning Effectiveness of 
Drycleaning with Carbon Dioxide” in the Appendix). 

In the DryWash system, liquid CO, at 54°F-58°F and 
700 pounds per square inch is pumped from a storage tank into the 
cleaning vessel, and a recirculating loop through a lint trap and filter 
train is established. During the cleaning cycle, the CO, must remove 
three types of soil: soil soluble in C0 2 , soil soluble in water, and soil 
insoluble in both CO, and water (pigment soil). 

The C0 2 -soluble soils, including many common organic stains 
such as body oils, dissolve in the nonpolar, liquid CO, and are 
carried from the cleaning vessel. The water-soluble soils, such as 
salts, are usually removed by agitation but may require pretreatment 
with a detergent that helps the soils dissolve in C0 2 . Pigment soils 
are the most difficult type of soil to remove. They are chemically 
bound to garments through surface tension, electrostatic forces, and 
Van der Waals forces, or they are mechanically trapped between 
two adjacent fibers of the fabric. Removing them involves two steps: 
(1) breaking the chemical bonds and dislodging the trapped panicles 
and (2) removing the pigment-loaded C0 2 from the cleaning vessel. 

The design of the cleaning vessel makes DryWash particularly 
effective at removing pigment soils. The garments are held in a 
perforated basket inside a stationary cleaning vessel (see diagram). 
To get mechanical action equivalent to that of the rotating basket 


1997 R&D 100 Joint Entry 


Page 4 


DrvWash™ 








Begin Proprietary Information 



Nozzle 

marufold(s) 


Perforated basket and 
jet configuration: side view 


Perforated basket and 
jet configuration: end view 


End Proprietary Information 


in conventional dry-cleaning equipment. Dry Wash uses a process 
called hydrodynamic agitation, in which nozzles located on the inside 
periphery of the basket spray high-speed jets of liquid CO, onto the 
garments. The jets soak the garments in CO, and create a vortex that 
causes the clothes to spin around inside the basket. As the outermost 
garments pass through the fluid jets, they momentarily accelerate and 
stretch slightly; once they have moved away from the jets, they relax 
and return to their original size. This stretch-relax cycle effectively 
dislodges particles. The layer of peripheral fluid immediately carries 
the dislodged particles out through the drain without penetrating the 
bulk of the load. This process minimizes the amount of soil that is 
redeposited on other garments (see “DryWash™: A Revolutionary 
Garment Dry-Cleaning Technology with Liquid Carbon Dioxide” 
in the Appendix). 

At the end of the cleaning cycle, the liquid CO, drains from the 
cleaning vessel to the storage tanks, which are connected to a still 
equipped with a heater. As the CO, is converted to a gas in the still, 
the dirt carried from the garments collects at the bottom of the still; 
this dirt is the only waste generated in the DryWash process. The 
clean, gasified CO, is then recondensed into the storage tank for use 
in the next cycle. More than 90% of the CO, is recovered in each 
cycle. Because CO, has a low surface tension and evaporates rapidly, 
only a short, “cold” (54°F-58°F) drying cycle is necessary. As a result, 
the entire cleaning process takes 18-25 minutes, approximately half 
the time of conventional dry-cleaning processes. 

The short video accompanying this entry, which includes portions 
of a CNN segment aired October 27, 1996, provides an overview of 
our DryWash process. A photograph of the Drywash machine, a letter 
of endorsement from the EFA, and articles explaining Drywash's 
effectiveness and environmental benefits are included in the Appendix 


1997 R&D 100 Joint Entry 


Page 5 


Dn’Wasli™ 







JO A. List of competitors 


Many companies worldwide use the following dry-cleaning 

solvents and associated equipment: 

1. Perchloroethylene (perc)—a chlorinated organic solvent that is 
currently used by more than 90% of cleaners in the US. 

2. Petroleum—known as Stoddard solvent, it contains a range of 
light hydrocarbons. It was once the primary solvent in the dry- 
cleaning industry, but less than 10% of dry cleaners now use it. 

3. Water—used as a primary solvent by less than 1% of US dry 
cleaners. Wet cleaning technologies that use specialized 
detergents are currently being developed. 


1997 R&D 100 Joint Entry 


Page 6 


Dn’Wash™ 


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IOC. Improvements on 
competitive technologies 


















The improvements of our DryWash system over competing 
technologies fall into three categories: (1) health, safety, and 
environmental benefits, (2) performance benefits, and (3) financial 
benefits. Petroleum-, perc-, and water-based technologies are all 
deficient in at least one of these categories; DryWash is the only 
dry-cleaning process that meets or exceeds expectations in all 
three categories. 

Health, safety, and environmental benefits. Liquid CO, is a 
readily available solvent that produces no hazardous wastes or 
emissions, will not deplete the ozone, and is nonflammable and 
odor-free. Because the CO, is under high pressure, a minimal risk of 
rupture exists, but DryWash uses CO, at pressures no higher than 
those in soda fountains at restaurants. Both petroleum and perc pose 
far more serious health and safety hazards. Petroleum is a highly 
flammable solvent that easily explodes; perc is a hazardous toxic 
substance that may cause cancer (see “A Cleaner Bill of Health” in 
the Appendix). Many local, state, and federal ordinances prohibit 
or limit the use of petroleum, stringently restrict perc emissions, 
and force dry cleaners to dispose of used perc solvent and perc- 
contaminated filters as hazardous wastes. Water, touted as an 
environmentally friendly solvent, has its own set of shortcomings. 

In many parts of the world, water is a scarce resource, but cleaners 
do not distill and recycle water used in dry cleaning. Depending on 
the chemicals that have been added in the cleaning process, the 
wastewater may be considered a hazardous waste. 

Performance benefits. The DryWash system not only uses a 
more environmentally friendly solvent than competing technologies, 
but the system also performs better. When we tested the cleaning 
performance of CO,, perc, and water on “dirty” fabric samples 
(containing ground-in soils, including C0 2 -soluble, water-soluble, 
and pigment soils), we found that C0 2 removed more dirt than perc 
did. Furthermore, we are currently developing new detergents that 
should considerably increase DryWash’s ability to remove dirt. 
Although we also cleaned the fabric samples in soap and water, these 
results are inaccurate for wet cleaning, which uses specialized 
chemicals rather than standard soaps. (See “Fabric Compatibility and 
Cleaning Effectiveness of Drycleaning with Carbon Dioxide” in the 
Appendix for test results.) 

Of all the dry-cleaning technologies, DryWash is the most 
effective at removing pigment (insoluble) soil. Its high-speed fluid 
jets greatly reduce pigment-soil redeposition (graying) because the 
CO, carrying dislodged soil does not penetrate the bulk of the load 
and because the high-speed flow of the solvent quickly removes the 


1997 R&D 100 Joint Entry 


Page 8 


DryWash™ 





displaced soil. In the other technologies, which rely on rotating 
baskets to agitate the garments, dislodged particles become 
sandwiched between the layers of the load and are easily 
redeposited. 

The DryWash system offers several other performance benefits. 
In water-, perc-, and petroleum-based methods, the heated drying 
cycles (at about 140°F) often set in stains and wrinkle or shrink 
garments, which then require significant amounts of finishing labor. 
In the DryWash process, however, liquid CO, is simply converted to 
a gas and evaporated from the garments at about 54°F-58°F. The 
lower temperatures set in fewer stains and wrinkles and, as a result, 
reduce the amount of finishing labor necessary. These temperatures 
also make DryWash faster and more energy-efficient than the 
competing methods. In addition, liquid CO, will not cause the fading 
and dye transfer in colored garments that water, perc, and petroleum 
can cause. Because liquid CO, is a more gentle solvent than perc, 
CO, can clean “problem” materials such as leathers and furs as well 
as accessories such as sequins without damaging them. 

Financial benefits. DryWash is also cost-effective. At $0.50 per 
pound, CO, is a cheaper solvent than either perc ($5-$7 per pound) 
or petroleum. In addition, DryWash minimizes the costs of 
environmental compliance, such as costs of hazardous waste 
disposal and new emissions-control equipment. Cleaners using perc 
must pay l%-3% of gross receipts for hazardous waste disposal. In 
some states, they must also pay solvent taxes of $ 1—$ 12 per gallon of 
perc purchased and annual fees of $100-$2250 for clean-up of perc- 
contaminated sites. Initial investment for the DryWash equipment is 
approximately equal to that for the current fifth-generation perc 
systems, but the DryWash equipment is iess expensive to operate. 
Because the process (including the drying cycle) operates at low 
temperatures, it does not wrinkle garments or set in stains. 

Therefore, DryWash also dramatically reduces the need for costly 
finishing labor and nearly eliminates liability costs associated with 
damaged garments. 

/ JA. Principal applications 


The DryWash process can be used to clean almost all types of 
fabric encountered in the dry-cleaning industry, including those that 
cannot be cleaned by current perc technology, such as leathers, furs, 
suedes, and sequined garments. Seven machinery manufacturers and 
five chemical companies will be licensed to produce equipment and 
supplies for the DryWash process. 


1997 R&D 100 Joint Enin' 


Page 9 


DryWash™ 


I IB. Other applications 


11C. Future applications 


12. Summary 


Currently, DryWash is used for cleaning textiles, such as 
garments, linens, and throw rugs. This application affects billions of 
people worldwide who rely on retail dry cleaners or industrial 
laundries at hotels, military installations, hospitals, nursing homes, 
and corporate facilities. 


Our DryWash system and fluid jets could be used in other 
applications, including the following: 

• Dishwashing: minor modifications to the cleaning vessel, such as 
adding dish racks, would allow restaurants and other food services 
to use DryWash. 

• Cleaning in the home: scaling down the size of DryWash, 
decreasing its cost, and expanding the delivery network for carbon 
dioxide could allow households to use small DryWash systems for 
laundry or dishwashing in the home. 

• Degreasing and decontaminating machined parts: after modifying 
the fluid jets to deliver supercritical carbon dioxide, we expect 
DryWash to be more effective than current supercritical cleaning 
devices at removing grease and grinding particulates (such as 
cerium oxide and diamond dust). 

From industrial laundries that service hotels, military 
installations, and hospitals to retail dry cleaners that cater to the 
public, the garment-cleaning industry affects billions of people and 
generates nearly $20 billion in worldwide revenue each year. The 
global demand for dry cleaning is increasing as garments become 
more specialized, economic development continues, and consumers 
find themselves with less time to clean their own clothes. 
Unfortunately, dry cleaning has its costs, not just to our pocketbooks 
and to the fabric in our clothes or linens, but also to our health and 
our environment. 

Currently, most of the health and environmental risks in the 
dry-cleaning industry are caused by the cleaning solvent perc. 

A suspected carcinogen with a strong odor, perc is hazardous to 
workers who handle it directly, to consumers who breathe the 
residual solvent on their freshly cleaned garments, and to apartment 
residents who inhale the fumes that escape from perc-based 
equipment in dry-cleaning establishments beneath their apartments. 
Although perc’s emissions are regulated under revisions to the Clean 
Air Act and under various state regulations, in October 1995 the 
Consumers Union reported that even the most modem perc 
equipment does not necessarily prevent perc levels from exceeding 


1997 R&D 100 Joinl Entry 


Page 10 


DryWash™ 








safe limits (see the summary from “Upstairs, Downstairs” in the 
Appendix). Nationally and internationally, the costs of 
environmental compliance for perc have skyrocketed to the point 
that many cleaners literally cannot afford to operate. 

Because of the hazards and costs associated with perc, it seems 
inevitable that perc will gradually be phased out, provided that an 
adequate replacement exists. Dry cleaners desperately need a 
replacement solvent that cleans effectively but that is 
environmentally friendly and cheap. Petroleum is not a contender— 
it has already been phased out because of its fire hazard. Water is not 
a viable alternative either because it damages many types of fabrics 
and/or requires excessive amounts of finishing labor. Currently, the 
only alternative that fits all the characteristics is our liquid-CO, 
DryWash system. 

Dry Wash poses very few health, safety, or environmental 
hazards. Not only does it effectively clean a wider variety of clothes 
and remove pigment soil better than any other dry-cleaning solvent, 
but DryWash is also faster and less expensive. Carbon dioxide is a 
virtually inexhaustible resource that is readily available from 
refineries, calcine furnaces, and breweries; and because other 
industries use C0 2 (to carbonate soda, for example), a distribution 
network for it already exists. Introducing C0 2 into the dry-cleaning 
industry will benefit cleaners and society as a whole through lower 
costs, better service, and improved environmental conditions. 

The same benefits will extend to future DryWash applications in 
cleaning home laundry, washing dishes, and cleaning industrially 
machined parts. 

Because of its tremendous worldwide benefits, DryWash was 
recognized in the 1996 “Best of What’s New,” Popular Science’s list 
of the year’s 100 greatest achievements in science and technology. 
Popular Science readers, who could vote on-line for their favorite 
technologies from the list, also honored DryWash with the Readers’ 
Choice Award. 


1997 R&D 100 Joint Entry 


Page 11 


DryWash™ 


Organization Data 


13. Chief executive officer 


14. Contact person to handle all 
arrangements on exhibits, 
banquet, and publicity 


15. To whom should reader 
inquiries about your product be 
directed? 


Name 

Dr. Siegfried S. Hecker 

Position 

Director 

Organization 

Los Alamos National Laboratory 

Address 

Mail Stop A100 

City, State, ZIP 

Los Alamos, NM 87545 

Country 

USA 

Phone 

(505) 667-5101 

Fax 

(505) 667-2997 


Name 

Melissa Miller 

Position 

R&D 100 Coordinator 

Organization 

Los Alamos National Laboratory 

Address 

Mail Stop C331 

City, State, ZIP 

Los Alamos, NM 87545 

Country 

USA 

Phone 

(505) 665-5377 

Fax 

(505) 667-0603 


Name 

Craig M.V. Taylor 

Position 

Technical Staff Member 

Organization 

Los Alamos National Laboratory 

Address 

Mail Stop E537 

City, State, ZIP 

Los Alamos, NM 87545 

Country 

USA 

Phone 

(505) 665-3545 

Fax 

(505) 667-6561 


1997 R&D 100 Joint Entry- 


Page 12 


DrvWash™ 


Appendix 

List of Co-developers 

Figure 1. Photograph of Dry Wash machine 

Endorsement letter from the EPA 

“Carbon Dioxide as an Environmentally Conscious Drycleaning 
Solvent,” a Los Alamos National Laboratory document 
presented at the Aerospace Hazardous Materials Management 
Meeting in San Diego, California, July 1996 

“Fabric Compatibility and Cleaning Effectiveness of Drycleaning 
with Carbon Dioxide,” a Los Alamos National Laboratory 
document 

“DryWash™: A Revolutionary Garment Dry-Cleaning Technology 
with Liquid Carbon Dioxide,” a Hughes Environmental 
Systems, Inc., document (reprinted with approval from Hughes 
Environmental Systems, Inc.) 

Summary from “Upstairs, Downstairs: Perchloroethylene in the Air 
above New York City Dry Cleaners,” a Consumers Union 
special report from October 1995 

“A Cleaner Bill of Health” from the May 1996 issue of 
Environmental Health Perspectives 

Profiles of Global and Hughes 

Los Alamos Profile 


Eight copies of a 4-minute video tape accompany this entry. 


1997 R&D 100 Joint Entry 


Page 13 


Dry Wash™ 


List of Co-developers 


Name W. Dale Spall 
Position Senior Researcher 
Organization Isotag, LLC, Isotag Research 
Phone (505) 662-6933 
Fax (505) 662-9033 

W. Dale Spall was the former principal investigator of the Dry Wash 
project at LANL. 










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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 


Dr. Craig Taylor 

Los AJamos National Laboratory 

SM30 

Bikini Atoll Road 
TA35/125/01U mail Stop E537 
Los AJamos, NM 87545 


OFFICE OF 

PREVENTION. PESTCIOES AND 
TOXIC SUBSTANCES 


Dear Dr. Taylor: 

As you are well aware, the U S Environmental Protection Agency has been extremely interested 
in the area of investigating new alternative solvents which will be safer to human health and the 
environment. One of the projects that we have been pursuing for several years under the Design 
for the Environment/Green Chemistry Program is the area of dry cleaning Because of the 
environmental concerns that have been raised with regard to certain dry cleaning technologies, 
EPA has been trying identify ways that the risks from these technologies could be reduced or 
mitigated. It is exactly for these reasons that we at the EPA find the research and development of 
the DryWash process to be so exciting 

The DryWash system using liquid carbon dioxide as the solvent for dry cleaning not only 
addresses the problems associated with hazardous solvents but it does so in an innovative and 
revolutionary way. What truly amazes me as a scientist is the time frame wherein this process was 
developed. To conduct such remarkable basic research and development and bring it to the 
implementation and commercialization stages in such a short period is an exceptional 
accomplishment. 

The impacts of this new DryWash technology will hopefully be felt not only in the United States 
but internationally as well I view this approach to be a quantum leap forward in protecting 
human health and the environment from the risks from hazardous solvents and EPA is pleased to 
be associated with this endeavor. 


Sincerely, 



Paul T Anastas, Ph D 
Chief, Industrial Chemistry Branch 
Office of Pollution Prevention 
And Toxics 


Recycled/Recyclabte •Printed witn Vegetable OH Based Inks on 100% Recycled Paper (40% Postconsumer) 





CARBON DIOXIDE AS AN 
ENVIRONMENTALLY CONSCIOUS 
DRYCLEANING SOLVENT 


W. Dale Spall 

Los Alamos National Laboratory 


ABSTRACT 

Carbon dioxide (C0 2 ) offers an environmentally sound replacement solvent to the 
currently used drycleaning solvent, perchloroethylene (PERC). In addition to the health 
and safety benefits of a C0 2 based cleaning system, large savings in solvent costs 
provide an incentive for conversion to the new system. Lower operating costs for the 
new technology provide further incentive. Projected energy savings for the current year 
are 2.18x10 12 BTU if this technology were to be fully accepted by the industry. 


CARBON DIOXIDE AS AN ENVIRONMENTALLY 
CONSCIOUS DRYCLEANING SOLVENT 


W Dale Spall 

Los Alamos National Laboratory 


The technique of drycleaning has been practiced in the United States for more than 150 
/ears, and has seen many changes during that time. In essence, drycleaning is a 
nonaqueous method for removal of soils from fabrics, especially from garments not 
compatible with water washing due to shrinkage, or dye incompatibility. The term has 
become synonymous with the cleaning of suits and fine clothing, specifically for spot 
and oily residue removal. Spot removal per se is really a separate part of the 
drycleaning process and constitutes hand application of selected solvents to affect the 
removal of the spot before the actual drycleaning process but since this has traditionally 
been done at the time of the drycleaning, the two are inexorably intertwined. Institution 
of a different solvent system would not alter the spot removal portion of the cleaning 
process. 

Initially, drycleaning used spirits of turpentine for the removal of oils and greases, but 
the unpleasant odor left on the garments forced research into other cleaning media. 

One of the main solvent systems developed during the 1920's was petroleum based 
Stoddard solvent. Stoddard solvent is still used in about 10% of all commercial 
drycleaning units today. In the late 1920's, chlorinated hydrocarbons were being 
developed and used in the drycleaning units of that time. In the 1930’s, 
perchloroethylene (PERC), another chlorinated hydrocarbon with good drycleaning 
solvent properties, became available. Due to its gentleness with fabrics and dyes, this 
solvent now dominates the US drycleaning market, with an annual usage of more than 
200 million pounds. 

There are currently 30,000-40,000 PERC drycleaning units in the US. This figure does 
not include systems using Stoddard solvent (10%) or other solvent systems (1%). 

These drycleaning machines are for the most part small machines used in small to 
medium sized businesses. The average new unit costs $50,000, and is called a dry-to- 
dry unit, in which the clothing is placed into the unit dry, the cleaning operation carried 
out, and the garments removed in the dry state, ready for return to the customer This 
type of unit is dictated by the emission regulations for PERC, both from an 
environmental perspective as well as a worker health and safety standpoint. The PERC 
loss from these units has decreased over the years since 1930 so that current PERC 
losses are about 0.5 to 1% of the 200 gallons used per cycle Since one 55 gallon drum 
of PERC can wash about 30,000 - 40,000 pounds of clothes, the amount of PERC used 




The drycleaning industry will require time and research to find a suitable replacement 
for PERC. to retool the industry for the manufacture of new equipment, and to place the 
new equipment in the field In the meantime, costs for the solvent PERC are rising from 
a current cost of $5.00 per pound to an estimated $7 00 per pound by the end of the 
year. In order to maintain this industry and the jobs it represents, new technologies for 
drycleaning must be found Increasing environmental controls resulting in increased 
capital outlays and increased operational costs resulting from rising PERC costs will 
cause consumers to purchase less garments requiring drycleaning, and the drycleaning 
industry will fade This could ultimately mean the loss of up to 200.000 direct jobs, and 
as many as 1.200,000 total jobs from the decline of the industry 

One promising solvent technology which can serve as a replacement for PERC is 
carbon dioxide Carbon dioxide (C0 2 ) is derived from two sources, either as a by 
product of air distillation or from ground wells rich in the gas. C0 2 is environmentally 
benign; it is a non-toxic, non-flammable gas at ordinary conditions When compressed 
to either its liquid or supercritical state, it becomes a excellent solvent for many of the 
types of compounds which are currently removed by PERC from garments, indicating 
that it would be a good solvent for use as a PERC replacement. The primary 
disadvantage of C0 2 as a solvent is that elevated pressures are required for its use. 
which could cause the equipment costs to be higher than those associated with PERC 
operations Prudent engineering should be able to keep the price equal to the current 
PERC machine costs, and since the recovery of the solvent is an inherent portion of the 
equipment, any price differences in initial cost will be more than compensated for by the 
lower solvent cost and usage anticipated with C0 2 . Current PERC units have been 
modified to minimize fugitive emissions of the PERC. C0 2 units are inherently closed 
systems due to the pressure requirements, so that solvent loss control is built into the 
units. High solvent recovery, low operating costs and performance equivalence to 
PERC machines are the hallmark of C0 2 equipment under design 

The economics of C0 2 use are appealing. C0 2 costs about $0.05 per pound, and can 
be readily separated from the soils found in dry cleaning Residual C0 2 on garments 
constitute a harmless release. Initial studies indicate that little C0 2 is retained by the 
garment, further limiting the already low solvent losses and fugitive emissions 
Assuming the cost of the PERC to be $5.00 per pound, and C0 2 cost to be $0.05 per 
pound, a factor of 100 in solvent costs would be recognized each year. This amounts to 
approximately 900 million dollars solvent cost savings to the industry yearly. If the 
energy saved per pound of PERC is assumed to be equal to the energy of formation of 
the compound, this corresponds to 4.17x10 n BTU per year energy saved at current 
solvent usage 

We believe it possible to produce a drycleaning machine which uses C0 2 as the solvent 
for the same cost as current dry-to-dry PERC units, about $50,000, making the 
purchase of a C0 2 unit equal in initial capital costs to that required for a PERC 
machine The average PERC use per unit is 5 000 pounds, at a cost of $25,000 per unit 


FABRIC COMPATIBILITY AND CLEANING EFFECTIVENESS OF 
DRYCLEANING WITH CARBON DIOXIDE 


S.B. Williams, K.E. Laintz*, W.D. Spall*, L. Bustos, and C. Taylor 


Chemical Science and Technology Division, CST-12 
Los Alamos National Laboratory 
Los Alamos, New Mexico 87545 


ABSTRACT 

Liquid carbon dioxide (LC0 2 ) offers an environmentally sound replacement to the widely 
used drycleaning solvent, perchloroethylene (PERC). In addition to the health and 
safety benefits of a C0 2 based cleaning system, savings in solvent and operating costs 
provide an incentive for conversion to the new system. Experimental studies were 
conducted using C0 2 in both small scale and pilot scale test systems in order to address 
fabric compatibility with this alternative cleaning method. Results from these tests show 
that fabric shrinkage using C0 2 is controlled to the same level as current drycleaning 
methods. Additional tests evaluating the cleaning performance of liquid C0 2 drycleaning 
were performed. These results show the prototype liquid C0 2 cleaning system to be 
better than PERC at insoluble soils removal, and worse than PERC at inorganic salt 
removal. 


EXPERIMENTAL 

Materials 

Eight fabrics representing a complete range of commonly encountered drycleaned 
fabrics were used in the test series: cotton twill, acetate satin, linen suiting, dacron 
polyester, dacron cotton, polyester cotton, rayon, silk crepe de chine, and wool flannel. 

Equipment 

All test fabric exposures were performed using a 260D syringe pump fitted with a 
cylinder water jacket and controlled with a series D pump controller. SFE/SFC certified 
grade C0 2 containing a diptube and a 1500 psi helium headspace was delivered via the 
pump to a 200 ml modified commercial filter housing cell containing the fabric samples 
This exposure or extraction cell was submerged in a thermoregulated constant 
temperature bath. Water was circulated to the 260D syringe pump’s water jacket at the 
same temperature setting as the constant temperature bath in order to insure liquid C0 2 
delivery. The C0 2 exposure system allowed for static, no flow, and/or dynamic, 
continuous flow operation to be carried out by opening and closing the inlet and outlet 
valves The exit gas was vented through a 1/4 inch stainless steel tubing pressure 
restrictor at the end of the exposure. 

Los Alamos National Laboratory Report Number LA-UR-96-822 
•Current address: Isotag, L.L.C., Isotag Research. 1285 Trinity Dr., Suite B, 

Los Alamos, NM 87544 




Drycleaning Experiments 


Sets of two open mesh bags containing duplicate sets of the eight fabric samples for 
each experimental set were processed by two drycleaners. Each facility processed one 
bag using a standard 30-minute wash cycle with "clean” or fresh PERC with no additives 
and the second bag with "dirty” or used, end-of-cycle PERC with additives, the second 
cycle assumed to be more representative of a standard drycleaning wash cycle. The 
fabric samples in each of the bags were then analyzed accordingly. 

Soil Removal Studies 

Fabric performance testing standards, “virgin” (containing no soil) and “dirty” (containing 
a specific amount of ground-in soil), were obtained from the International Fabric Institute. 
The monochrome luminance values, the amounts of light reflected, were determined with 
the Optimas system. Soil removed directly correlates to a higher amount of light 
reflected and therefore a higher value. Values were obtained for the “virgin” and “dirty” 
standards by measuring four different areas'of each fabric standard three times The 
value for the standards was set to 100 or 100% for “virgin" and 0 or 0% for “dirty”. 

Nine fabric samples were processed as follows: C0 2 was the solvent in six runs; PERC 
the solvent in two runs; and soap and water in one run. Mesh bags containing duplicate 
“virgin” and “dirty” fabric standards were processed at two drycleaners. Pre- and post¬ 
exposure measurements were obtained in three different areas on each of the fabrics for 
determination of soil removal. 

Salt Removal Studies 

Prior to conducting the salt removal experiments, fabric samples were first washed in a 
3:1 isopropyl alcohol/H 2 0 solution to remove potential interfering inorganic species 
After drying in a class-100 particulate hood, the washed fabrics were then spiked with 
NaCI at two contamination levels, 100 ng/g and 500 ng/g of fabric. Four sets of 
duplicate fabric samples spiked with the two concentrations of NaCI were processed. 
Two sets each of the same samples were processed by drycleaners using fresh PERC 
on one and dirty PERC on the other After the cleaning had been completed, the fabric 
samples were soaked overnight in 5 ml of (Dl) water. The concentration of NaCI 
remaining on the fabric samples after cleaning was then back-calculated based on the Dl 
wash concentration. 


RESULTS AND DISCUSSION 

The primary goal of these experiments was to determine the feasibility of LC0 2 as a 
replacement solvent for PERC in the existing drycleaning industry. Reports from 
attempts to use supercritical C0 2 as a drycleaning solvent replacement in Europe and 
pilot studies done in our laboratories indicated that although supercritical C0 2 was an 
excellent solvent for removal of body oils from fabric, the relative high pressures and 
temperatures involved required controlled pressure let-down to avoid fiber damage. This 
difficulty leads to long processing times, which is generally unacceptable to the 


bulk substrate. Both the degassing of CO 2 and the polymer fractionation could change 
the hand of the synthetic fabrics as well as contribute to shrinkage. From a natural fibers 
standpoint, LC0 2 will likely extract some of the natural oils and resins that they contain. 
While this phenomenon could potentially change the hand of the fabric, it is unlikely to 
cause significant shrinkage. For these reasons, weight change was selected to test the 
compatibility of various fabrics in LC0 2 . 

The eight fabric test materials were placed in a small 200 ml vessel and exposed to 
LCO 2 for 10, 20, and 40 minutes at potential cleaning conditions along the C0 2 boiling 
line (Figure 1). Initial weight measurements were made immediately following, at 24 
hours, and at 48 hours after exposure. The data was averaged for all fabric samples 
and is summarized in Table 1. As seen in Table 1, exposure to LC0 2 at 0% relative 
humidity resulted in a weight gain in most of the fabrics which was attributed to C0 2 
absorption. Conversely, the fabrics conditioned at 70 and 100% RH had from 1-5% 
weight losses immediately after exposure to LC0 2 . Since a majority of this weight loss 
can be attributed to the loss of water from the fabrics, weight measurements were taken 
4 days after exposure to ensure complete degassing and to re-establish equilibrium 
moisture content within the fabric. However, in the extreme cases of weight loss( more 
than 3% of original weights) compounds were extracted from the fabric which resulted in 
shrinkage. For example, at 0 and 70% RH diacetate had approximately a 3% average 
weight loss. Since it is believed that C0 2 was extracting lower molecular weight 
oligomer fractions from diacetate, this weight loss was accompanied by significant 
shrinkage, which will be discussed later. As a solvent, C0 2 is much more efficient as an 
extractant when it is modified with a polar cosolvent such as water. For this reason, 
higher weight loss and corresponding shrinkage were expected to occur with higher 
water concentrations. This was indeed observed as presented in Table 1, especially at 
100% RH. It was found that wool had a significant weight loss at 100% RH. The extract 
from a wool sample that had been exposed to LC0 2 at 1000 psi and 25 °C was collected 
to determine what was contributing to this loss in weight. The extract was analyzed by 
gas chromatography using a mass selective detector and found to contain lanolin-like 
compounds. 

Several conclusions are obvious from the data summarized in Table 1. The dominant 
factor in weight loss due to LC0 2 exposure is relative humidity. The more water in the 
system, the greater the overall weight loss This is believed to be primarily due to the 
solvent action of the water modified LC0 2 extracting compounds out of the fabric matrix 
as well as removal of water from the polymer. The fabrics that were conditioned at 100% 
RH prior to LC0 2 exposure had an overall weight loss of -2.8%. In contrast, those 
fabrics conditioned at 70% RH had an overall weight loss of only -0.6%, and those 
conditioned at 0% RH posted an overall weight gain of +0.9%. While pressure is 
certainly expected to effect the solvent strength of LC0 2 and thus weight loss, it 
appeared to be a factor only at 100% RH. In this case the fabrics exposed at 700 psi 
and 10 °C, (LC0 2 density of 0.86 g/ml) had an average weight loss of -3.2% while those 
exposed at 1000 psi and 25 °C, an LC0 2 density of 0.74 g/ml, had an average weight 
loss of -2.3%. At high humidity, the higher the density, the greater the weight loss. 
Again, this is due to the solvent power of LC0 2 . where in general, the greater the density, 
the greater the solvent strength. Finally, exposure time was not a significant factor as far 
as overall weight loss was concerned. 




Soil Removal 


In addition to fabric compatibility studies, general cleaning comparisons were also 
conducted. One measure of cleaning performance commonly used to measure the 
quality of the cleaning method is the removal of rug soil from fabric. Commercial rug soil 
standards are commonly used to rate the performance of different cleaning processes. 
The standards consist of 4”x6” pieces of cotton fabric that have been impregnated with 
rug soil, labeled as "dirty”, and attached to a conventional garment. The rug soil is 
industrial vacuum dust which is ground into the fabric using a ball mill. The removal of 
this soil by the cleaning process is a general gauge of the agitation present within the 
cleaning vessel as well as a measure of the soil suspension ability of the cleaning fluid. 
There is also a baseline clean fabric performance testing standard that contains no 
ground in rug soil, and this standard is labeled as “virgin” Hughes Environmental 
Systems, Inc. processed dirty fabric performance standards using the prototype LC0 2 
drycleaning machine with vigorous agitation. The cleaned samples were then compared 
with dirty fabric performance standards that had been run at local drycleaners using 
PERC both with and without detergent additives. Finally, for comparative purposes, a 
dirty fabric standard was also cleaned using conventional soap and water laundering 
These cleaned fabrics were then compared to the initial virgin and dirty samples to 
assess overall soil removal efficiencies. These results are summarized in Table 3. 

From the data presented in Table 3, it can be seen that standard soap and water 
provides the best result for the removal of ground-in soil. This is expected since the 
detergent functions as a flocculant to disperse and suspend particulate soil. In fact, this 
is one reason why detergents are added to PERC to enhance the overall drycleaning 
process. PERC with detergent additives was far superior to PERC without additives in 
removing the rug soil from the test standards. Moreover, the test standards that were 
run in PERC without additives actually came out with more dirt on them than when they 
were initially placed into the drycleaning vessel or wheel. This can be explained as a 
redeposition of soil. This makes the sample appear “dirtier than it was prior to 
treatment. High redeposition is usually a sign of inadequate flow, washer overload, or 
improper filtration (process maintenance deficiencies). While the “charged” PERC, or 
PERC with detergent additives, performed adequately, LC0 2 proved superior using 
appropriate agitation. 

Salt Removal 

In order to gauge the effectiveness of the different cleaning methods at removing water- 
soluble soils, the removal of salt was investigated The primary soil of this type found in 
garments would be sweat, and for this reason, the removal of sodium chloride (NaCI) 
was tested. Water-soluble soil removal is one of the reasons detergents are currently 
added to PERC in conventional drycleaning. The detergent helps to solubilize water in 
the PERC, and this water is what actual dissolves this type of soil in the cleaning 
process. For comparative purposes, PERC with and without detergent additives was 
investigated. It is common knowledge that LC0 2 by itself is ineffective at solubilizing 
water-soluble materials such as salt. It has been shown that using supercritical C0 2 with 
a high flow rate is much more effective than with a low flow rate in a cleaning process for 
the removal of low solubility contaminants. In addition, unrelated studies in our 


known that PERC does an excellent job at removing oil and grease type organic based 
stains. It is also known from our previous work that LC0 2 is an excellent solvent for 
these same residues, especially body oils. For these reasons, the removal of organic 
based soils from the test fabrics was not studied. Drycleaning with PERC is not 
particularly effective in removing inorganic or food based stains. Previous work has also 
shown the relative ineffectiveness of LC0 2 at removing the same types of soils 
Currently, such stains are pretreated using various spotting methods prior to drycleaning 
in PERC. It is assumed that the same pretreatment would also be used when cleaning 
with LC0 2 for the removal of the same types of soils. While spotting applications have 
yet to be tested, commonly used spotting solutions were sprayed onto fabric test 
samples. These samples were then run in the prototype machine. It was found that all 
of the spotting solutions tested were compatible with LC0 2 cleaning in that they were all 
removed from the fabric test samples. 

During the course of the investigation, several “problem” fabrics were tested to 
determine the effects of the LC0 2 and PERC cleaning on the fabrics. Leather and fur 
goods present a special problem for drycleaning, due in part to the incompatibility of the 
fabric with the solvents. The leather and fur fabrics tested for compatibility with the LC0 2 
process showed no loss of hand and complete removal of body oil soils. These tests 
were not extensive and should be considered with care. 

The compatibility of notions on the various fabrics is a concern to drycleaners, so a brief 
study of the effects of the LC0 2 process on buttons, sequins, metallic thread and fabric, 
zippers, and closures was done. In general, there were no adverse effects observed for 
any of the materials tested. Normal buttons show no effects whatsoever, with no weight 
loss even after repeated exposures. Sequins, metallized fabric and thread, zippers, and 
closures reacted similarly. Repeated exposures of metallized fabric caused some 
delamination in one case and no effects in any of the other cases. Sealed metallic 
buttons having an internal air space tended to deform due to the pressure of the LC0 2 
operating conditions. 


CONCLUSION 

Liquid C0 2 is certainly not a drop-in replacement for PERC drycleaning; however, it is 
known that liquid C0 2 is an effective solvent for the removal of common types of organic 
soils. From this standpoint, LC0 2 can potentially replace PERC as an environmentally 
friendly drycleaning solvent. Experimental studies have shown that LC0 2 processing 
had no deleterious effect on test fabrics. In general, LC0 2 processing results indicate 
that pressure/density has no significant effect on shrinkage or weight loss. However, 
higher humidity or water content results in greater shrinkage and weight loss, with 
shrinkage being greater with longer exposure times. Nevertheless, shrinkage from LC0 2 
processing and cleaning was within acceptable standards, and LC0 2 cleaning had much 
better soil removal performance than standard PERC drycleaning. Work is underway to 
evaluate full scale prototype cleaning units, and the data from these ongoing studies 
should present a clear determination of the capabilities of drycleaning with LC0 2 . 





Table 1. Average percent weight change for all fabrics. 


co 2 

Pressure 

Humidity 

Immediately After 
C0 2 Exposure 

After 2-4 Days 
Equilibration* 

Equilibration 

After 10 C0 2 Exposures 

700 psi 

0% 

+ 2.58 

-0.50 

+ 1.13 


70% 

- 1.17 

-0.82 

+ 0.27 


100% 

- 3.46 

-0.89 

- 5.26 

800 psi 

0% 

+ 4.19 

-0.52 

+ 1.05 


70% 

-0.61 

-0.25 

- 1.02 


100% 

- 2.31 

- 1.74 

-4.00 

900 psi 

0% 

n/a 

-0 03 

+ 0.54 


70% 

-0.37 

- 0.50 

- 0.31 


100% 

-2.06 

-2.30 

-4.68 

1000 psi 

0% 

n/a 

0.00 

+ 1.40 


70% 

- 1.13 

- 0.74 

- 0.24 


100% 

- 1.86 

- 0.34 

-4.79 


Average weight error is ± 0.34% 


•Post equilibration time was 2 days for samples run at 0% RH and 4 days for samples run at 70 and 100% 
RH. 


Table 2. Average percent shrinkage for LCQ 2 exposure. 



0% Humidity 

70% Humidity 

100% Humidity 

Cotton 

+0.56 % 

-0.82 % 

-0.52 % 

Diacetate 

-3.34 

-2.80 

-1.95 

Linen 

+0.66 

-0.77 

-0.80 

Polyester 

+0.54 

-0.95 

-0.87 

Polyester-Cotton 

+0.59 

-0.75 

-0.74 

Rayon 

+0.70 

-0.85 

-0.16 

Silk 

+0.69 

-0.91 

-1.62 

Wool 

+0.89 

-0.63 

-1.30 


Table 3. Comparison of average soil removal efficiency 


Cleaning Method 

Percent Soil Removal 

co 2 

57.99 ± 3.2 

PERC with additives 

35.51 ± 12.7 

PERC without additives 

-31.41 ± 12.3 

Soap and water laundry 

80.67 ±6.7 


Table 4. Comparison of average NaCI removal efficiencies 



co 2 

high rate of mixing standard rate of mixing 

100 pg spike removal 

500 pg spike removal 

14.9 pg (14.9%) 

5.8 pg (1.2%) 

13.3 pg (13.3 %) 

8.0 pg (1.6 %) 


PERC 

“Dirty" “Clean" 

100 pg spike removal 

500 pg spike removal 

46.4 pg (46.4 %) 

122.8 pg (24.6 %) 

31.6 pg (31.6 %) 

60.9 pg (12.2 %) 





























DryWash™ 

A REVOLUTIONARY GARMENT DRY-CLEANING TECHNOLOGY 

WITH LIQUID CARBON DIOXIDE 


Dr. Sid Chao 
Mariana Purer 
Carl Townsend 

Hughes Environmental Systems Inc. (HESI) 


ABSTRACT 


In its dense phase, both supercritical and liquid, carbon dioxide has good, organic- 
solvent-like properties. In its supercritical state, it has been extensively used for 
extractions, by the food and pharmaceutical industries. More recently, the use of liquid 
carbon dioxide has been expanded to general and precision cleaning of various 
substrates, as a substitute for hazardous, polluting, or ozone-depleting compounds. 

DryWash™ is a patented carbon dioxide garment dry-cleaning technology, that uses 
liquid carbon dioxide (LCO2) jets as a means of providing the mechanical action 
necessary for soil removal. 

This article briefly addresses the LCO2 jet agitation garment cleaning principles, the 
general performance of the DryWash™ process, substrate compatibility and the main 
features of a typical LCO2 dry-cleaning machine that embodies the DryWash™ process. 


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Environmental Systems Inc. 

Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved. 





INTRODUCTION 


All solvents used in the current, conventional dry-cleaning process present health, safety and 
environmental problems. Perchloroethylene (perc) is a suspected carcinogen, and the petroleum 
based solvents are flammable and smog producing. Containment, disposal and emission control 
costs are forever increasing equipment and operational costs. For these reasons, the industry is 
continuously searching for an acceptable, "green" alternative solvent and technology that can 
resolve these issues in a cost competitive manner. 

Carbon dioxide is an unlimited natural resource, an atmospheric component, at a 0.035% level by 
volume. It is non-toxic, non-flammable, non-smog producing, and non-ozone depleting. In its 
dense phase, both supercritical and liquid, it has good, hydrocarbon-like solvating properties (is a 
good solvent for fats and oils) that are well known and documented in the literature. Its low 
surface tension also gives it good wetting properties, thus natural detergency. It can be liquefied at 
relatively low pressures and the saturation pressure at room-like temperatures of 10-15°C is below 
800 psi. 

Because of its desirable physical and chemical properties, liquid carbon dioxide is a good 
candidate for use as a replacement solvent for garment dry-cleaning. Its properties in liquid state 
are compared to those of the conventional dry-cleaning fluids in Table 1 below: 

Table 1. 


SOLVENT 

TYPE 

SURFACE 

TENSION 

(Dynes / cm) 

DENSITY 

(gm / cm 3 ) 

SOLVENT 
POWER 
(K.B. value) 

VISCOSITY 

(centipoise) 

Perchloroethylene 

32.3 

1.6 

90 

0.88 (20°C) 

1,1,1,trichloroethane 

25.6 

1.4 

124 

1.2 (20°C) 

Petroleum (Cl 2) 

(Cl 8) 

27.6 

0.77 

27-45 

1.35 (25°C) 
2.86 (20°C) 

Liquid C02 

A3 

0.84 -0.9 

★ 

0.082 (12°C) 


* Calculated solubility parameters that incorporate both "chemical state" (polar-nonpolar, hydrogen bonding) and 
"physical state" (pressure and temperature) considerations, have indicated that liquid carbon dioxide (at or around 
1000 psi and 77°F) is most like trichloroethane. Experimental data indicates more petroleum-like solvent power. 


Our objective was to develop DryWash™, an alternate dry-cleaning process, based on Hughes- 
specific carbon dioxide technology, and do so at a competitive price. 

The approach has been to: 

a) set a target price range for the equipment that was to house the process; 

b) identify the main cost drivers in a high pressure cleaning machine, and; 

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Environmental Systems Inc. 

Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved. 











c) set developmental limits on these cost drivers, such that the pre-set equipment target 
price range can be met. 

The most obvious cost driver in a pressure system is the pressure itself: the higher the pressure, the 
higher the cost of every system component that has to contain it, and the higher the operational 
(energy) and maintenance costs. For this reason, the developmental pressure limit was preset at 
1000 psi, where the goal was the lowest working pressure under this value. This automatically 
placed the process development in the liquid state of the carbon dioxide . 

Although the public at large is more familiar with the use of the supercritical phase, given that it 
has extensive applicability in the food and drug industries, the higher pressure of the supercritical 
phase comes at a premium that the dry-cleaning industry cannot afford. In addition to this, liquid 
carbon dioxide is a better solvent: to achieve equivalent solvency in the supercritical state as in the 
liquid state, pressures of 2-3000 psi are required. Also, the pressure/temperature dependent solvent 
selectivity of the supercritical carbon dioxide, though it is a valued property in food and/or drug 
extractions, does not present an advantage in garment dry-cleaning. 

The second cost driver in a pressure system is the mechanical action. Agitation by the 
conventional mechanical means of a rotating basket, either through a break-through shaft or 
magna driver, is expensive, due to the cost of the drive itself, seal maintenance (for break through 
shafts), and the required large chamber diameters. For this reason, the developmental limit was set 
for an agitation method without mechanically moving parts. High velocity fluid jets were selected 
as a means for mechanical action. 

The process additives were identified as the third cost driver: the target was a process augmented 
by pre-spotters only. This objective was initially set based on the higher water solvency of the 
liquid carbon dioxide, and prior to any testing. 

PRINCIPLES OF FLUID JET AGITATION DRY-CLEANING OF GARMENTS. 

By simple definition, a cleaning process means soil removal, without substrate damage. In garment 
dry-cleaning three distinct types of soil are present: solvent soluble, water soluble and insoluble, or 
pigment soil. The mechanism of solvent soluble soil removal is one of simple dissolution, while 
the mechanism of removing water soluble soils is one of secondary solubilization, or co¬ 
solubilization. This article addresses mainly the pigment soil removal mechanism, as it represents 
the novel aspect of the LCCVDryWash™ garment dry-cleaning technology. 

The two steps of pigment soil removal in garment cleaning are the actual removal of the pigment 
off the garment and into the solvent, and, the transport of the pigment loaded solvent out of the 
cleaning drum, to prevent graying, or, redeposition. 

Pigment soils are bound to garments by two distinct types of mechanisms. The first mechanism 
consists of surface tension, electrostatic forcess and Van der Waals forces. The second binding 
mechanism is when the particles are trapped between two adjacent fibers. Pigment soil removal 
can take place only when the forces acting on the pigment particle exceed the binding forcess 
between the particle and the garment. 

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Environmental Systems Inc 

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In fluid jet cleaning, power for the process originates in a pump and is transferred to the particle as 
follows: 


Pump—> 

Differential-* 

Fluid—» 

Fluid—» 

Pigment 

power 

pressure AP 

velocity v 

momentum 

expulsion 


The garments are submerged in the LCO 2 within an enclosed cylindrical perforated basket (inside 
the cleaning drum, or pressure vessel). The load is then set into motion and agitated by high 
velocity fluid jets. The jets are discharged through the nozzles of manifolds set in an appropriate 
configuration, within the perforated basket as shown in Figure 1. (Note: this figure represents the 
unoptimized chamber configuration of the developmental prototype and is used only for 
illustration.) 

The cleaning zone is near the jet source, on the outermost periphery of the rotating load. The 
garments within the load are entrained by the high velocity fluid jets through a Venturi effect As 
they enter the high velocity jet cleaning zone, they experience a momentary acceleration. At a 
constant flow F, this acceleration is dependent on the pressure drop AP across the jet nozzles. As a 
result of this acceleration, the garments experience a stretch. As the garments exit the jet, or 
cleaning zone, they relax and snap back to size. This stretch-relax cycle repeats itself throughout 
the entire cleaning step and effects the pigment soil removal/expulsion. 



Fig. 1 Perforated basket and jet configuration: side view 

Because the cleaning zone (as described above) is on the outermost periphery of the rotating load, 
the dislodged pigment is carried out of the perforated drum by the peripheral fluid layer of the 
vortex / spiral (set up by the jets), and out of the vessel itself, through the exit port. It does not 
penetrate the bulk of the load. 


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The pigment soil concentration within the wheel at any one time is relatively low, since the load is 
cleaned outer-layer-by-outer-layer, the garments being entrained sequentially by the fluid jets. As 
such, the graying factor is inherently lower than in the conventional process. The graying factor is 
further lowered, since the flow demand is inherently higher in the fluid jet cleaning process (per 
equivalent load). The number of solvent exchanges per unit time is higher, and thus the soil 
residence time and redeposition, lower. 

To summarize, in fluid jet cleaning, where the cleaning fluid has a low viscosity, higher levels of 
cleanliness can be obtained since smaller ("graying") particles can be removed off the surface, and 
less redeposition will be noted, since the colloidal particles will have a shorter residence time in 
the wheel (higher pump capacity), and overall particulate soil concentration within the wheel is 
always low (peripheral cleaning zones). 

PROCESS PERFORMANCE 

Comparative surface reflectance results of pigment soil standards validate the pigment soil 
removal concept described above. As the differential pressure of the jets rises, soil removal 
improves: smaller, and more firmly embedded particles are removed. Thus, the higher the 
reflectance of the resulting surface. 

A comparative quantification of the jet cleaning mechanical action and the conventional drum 
mechanical action was performed by the Los Alamos National Laboratory, using International 
Fabricare Institute (IFI) rug soil standards. The reflectance values of jet cleaned standards were 
compared against the reflectance of the standards that were processed in ’common" cleaning loads 
by commercial dry-cleaning establishments, using charged (soap and water) perc. A standard that 
was cleaned by hand scrubbing with soap and water was also included in this evaluation. To 
increase resolution, the reflectometer was calibrated so that the "virgin" standard would read 100% 
reflectance, while the reflectance of the initial, soiled IFI, was set at 0%. The quantitative results 
are illustrated by the bar chan in Figure 2. 


Comparison of Soil Removal Capabilities 



IFI Clean Soap 4 C02 Perc Perc (No 

Water (Charged) Addrtives) 


Cleaning M ethod 

' Result is due to redeposition of soil 


Fig. 2. Pigment soil removal comparison 

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Copyright © 1996, Hughes Aircraft Company. An unpublished work. All rights reserved. 















































Overall process performance, was also evaluated in a more controlled fashion against the 
performance of the commercial perc cleaning process, both charged and uncharged. The results 
correlate closely with those obtained by independent equipment manufacturers, using industry 
accepted standards. 

Cleaning performance categories investigated were as follows: 

• oily soil removal 

• "collar dirt" 

• particulate soil removal 

• dye transfer 

• stain removal 

• whitening / redeposition 

• water soluble soil removal 

• cycle time. 

Within the process parameters (pressure and temperature) selected, the liquid carbon dioxide jet 
cleaning process performance compared to the perc cleaning process as follows: 

Table 2. 



Oily soil 

- * -~f> • •% ‘..Viu • J; K . ft .* , - * S_vw— -3 .* 

siS 


Particulate soil 1 



Stain removal 2 



Whiteningfredep; 




Water soluble soil 3 



iSyqletime 



Better 


Equivalent 




Equivalent 
Better 


:.**>• ss.: 


1 Indicates a "better-than" condition compared to an uncharged perc system, and equivalency when 
compared to a charged perc system 

2 In this case the equivalency indicated that stain removal without prespotting was equally poor for 
the LCO 2 , and perc (charged, or uncharged) 


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3 The water soluble soil removal capability of the LCO 2 was equivalent to that of the uncharged 
perc, and lower than that of a charged perc system. 

The results as illustrated above, indicate not only a practical equivalency, but also a "better than"- 
potential , compared to the conventional process performance, when incorporating additives or 
prespotters. 

Additives 

Liquid carbon dioxide is a non-polar dry-cleaning solvent, that primarily removes non-polar soils 
such as oil and grease. Since water soluble, or hydrophilic soils are polar or ionic in nature, they 
have a low solubility in liquid carbon dioxide (and other conventional dry-cleaning solvents). 

It is obvious that in order to efficiently remove common polar or ionic soils such as salt (from 
perspiration) and glucose (from beverages), LCO 2 compatible additives have to be introduced into 
the system, or pre-spotters used. They will either directly facilitate the co-solution of the above 
named soils into the liquid carbon dioxide system, or, increase the moisture transport ability of the 
liquid carbon dioxide. The solvated water, in its turn, can than dissolve the hydrophilic soils, 
through a secondary solubilization mechanism, as documented in conventional dry-cleaning. 


This document shall not be published or copied in whole or in part except with written permission of Hughes 

Environmental Systems Inc. 

Copyright® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved. 




COMPATIBILITY 


Common fabrics 

A number of common fabrics, both natural (cotton, silk, wool, linen) and synthetic (polyester, 
poly/cotton, rayon, diacetate) were repeatedly exposed to the process. Dimensional changes noted 
were within the same range as those produced by the conventional process. The shrinkage of the 
diacetate was above that of the conventional process. The evaluation was performed by the Los 
Alamos National Laboratory, and a report will be issued. Actual garments, both simple and of 
complex construction (i.e. jackets, with linings, shoulder pads...) were also processed repeatedly, 
without noticeable degradation or dimensional change. 

Also, vividly colored garments were co-processed with "lights" without noticeable color loss or 
transfer. 

Leathers and furs 

A number of vividly colored leather (finished one side, split the other), and fur samples were 
submitted to the jet agitated liquid carbon dioxide cleaning process and than compared against 
unprocessed standards, for visual damage and color difference verification. No color change, 
stiffening, brittleness, or general hand-and-feel change was noted on any of the samples. 

Actual leather garments were not processed due to the small chamber dimension. We expect this 
type of garment processing to be problem free, although loading ratios will likely be reduced due 
to their natural bulkiness. 

Leather work (machinist) gloves were also successfully cleaned. 

Buttons and decorations 

A large number of various common and decorative buttons (metallic, natural: shell and bone, and 
synthetic) were attached to fabric and were co-processed in a 0.4 (lb/gal) loading ratio load to 
simulate the maximum expected agitation in a cleaning load. The buttons were subjected to eight 
agitation cycles, 15 minutes each. No visual damage was noted on any of the buttons. Please note 
that none of the buttons had sealed cavities. We expect that any decorative buttons with sealed 
cavities would have to be removed off the garments prior to processing, to avoid being crushed by 
the pressure. 

Metalized sequins also appear undamaged. 

There is occasional weakening of the elastic inserts, not unlike that noticed in dry-cleaning 
processing with conventional cleaning fluids. 


This document shall not be published or copied in whole or in part except with written permission of Hughes 

Environmental Systems Inc. 

Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved. 


THE PRE-PRODUCTION DryWash™ MACHINE: SCALE-UP 


A typical DryWash™ cleaning cycle is is 18-24 minutes long and is comprized of a number of 
steps: fill, jet-agitation, drain, and vapor-recovery/decompression. A machine that houses this 
process has to accomodate these steps in the most cost efficient manner from the point of view of 
capital (machine) and operational (energy, labor, maintenance, solvent, cycle time) costs. 

An exemple process and instrumentation drawing incorporating the full technology is illustrated in 
Figure 3. Some notable aspects of this drawing include the reversible agitation, top side drain 
circulation, and the vapor recovery /load warming strategies, all designed to reduce energy 
consumption and cycle time. 



Fig. 3 DryWash™ Dry-cleaning machine 


SUMMARY 

All test results and economic analysis suggest that the DryWash™-liquid carbon dioxide jet 
cleaning process is not only a viable alternative for garment dry-cleaning, but it has the 'better, 
faster and cheaper" potential, compared to the conventional process, through further equipment 
optimization, scale up, and chemistry (soap) development 

References: 

1. Perry & Chilton, (Eds) Chemical Engineer's Handbook McGraw-Hill, 1973 

2. Musselman, et al. "Shear Stress Cleaning for Surface Departiculation", Journal of 
Environmental Sciences, Jan 1987 

3. Brandreth, D.A. and Johnson, R.E., "Removal of Particulates for Optical Lenses", the Optical 
Index’s Journal of Ophthalmic Dispensing, Jan 1979 

4. William H. Smith, Manfred Wentz, and Albert R. Martin," Comparison of Soil-Deposition and 
Redeposition Tests in Evaluating Drycleaning Detergents" National Institute of Drycleaning. 

This document shall not be published or copied in whole or in part except with written permission of Hughes 

Environmental Systems Inc. 

Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved. 























Upstairs, Downstairs: Perchloroethylene in the Air above New York City Dry Cleaners 

Consumers Union Special Report, October 1995 


SUMMARY 


Tests conducted by the New York State Health Department 
in 1991 demonstrated that the air in apartments located above 
dry cleaners is polluted with perchloroethylene ("perc," for 
short), the primary solvent used in dry cleaning. NYSDOH has 
called this "a high risk environmental health problem.” The 
state has also established 100 micrograms of perc per cubic 
meter of air (100 /xg/m 3 ) as a guideline for maximum safe long¬ 
term public exposure to this pollutant. 

In the NYSDOH study, the highest perc levels were found 
in apartments above dry cleaners that had old-fashioned dry- 
cleaning equipment; apartments above cleaners with more modern 
”dry-to-dry” equipment had lower, although still rather high, 
perc levels. In 1994, New York State concluded a negotiated- 
rulemaking process which produced a proposal to require all 
dry cleaners located in residential buildings to use modern 
unvented, dry-to-dry machines. The proposal has not yet been 
implemented by the Pataki administration. 

Our study examined whether the use of modern dry-cleaning 
equipment would produce acceptably low perc levels in the air 
of residences located above the cleaners. We selected 12 dry 
cleaners with modern, dry-to-dry machines, located in New York 
City apartment buildings, and tested the air in 29 apartments 
in those buildings for perc. We sampled for 24-hour periods, 
on four different days, in each apartment. 

We found that modern equipment does not prevent serious 
perc pollution of apartments above dry cleaners. Twenty-four 
of the 29 apartments had average perc levels above 100 /xg/m 3 , 
the state health guideline; eight apartments had average perc 
levels above 1,000 /xg/m 3 . The highest average perc level in 
an individual apartment was 2 5,086 /xg/m 3 . Exposure to perc at 
the levels we found in many apartments we tested poses a clear 
danger to the health of the apartments' residents. 

Although perc pollution from dry cleaners in residential 
buildings has been recognized as a significant public-health 
problem for several years, to date local, state and Federal 
governments have failed to solve the problem. These findings 
suggest that the approach currently being pursued by New York 
State, requiring all dry cleaners to install more modern dry- 
cleaning equipment, will improve the situation above cleaners 
with older equipment, but will not guarantee acceptably low 
perc levels in apartments' air. We recommend that the New 
York City building code be amended to prohibit dry cleaners 
from operating in residential buildings. We also recommend 
that people who live in apartments upstairs from a dry cleaner 
get their air tested for perc. 



Innovations 


Volume 104, Numbers, May 1396 - Environmental Health Perspectives 


A Cleaner Bill of Health 

Liquid carbon dioxide (C02) is getting serious consideration as the dry cleaning fluid of the future. With 
encouragement from the EPA's Design for the Environment program, liquid C02 could replace 
perchloroethylene-known as "perc"--today's dry-cleaning solvent of choice. Perc, a chlorinated hydrocarbon, 
has been linked to cancer and other health problems. 

Based on animal studies and other data, the International Agency for Research on Cancer (IARC) calls perc a 
probable human carcinogen. The EPA puts the solvent in the possible-to-probable category of carcinogens. 

James Huff, a toxicologist with the NDEHS, says perc-cleaned clothes pose virtually no cancer risk to the 
wearers; the amount of perc on such clothing is probably negligible. The NEEHS has reported, however, that 
rats exposed to perc vapors have an increased incidence of leukemia and kidney tumors, and mice similarly 
exposed have increased numbers of liver tumors. Moreover, Huff says, epidemiological studies have linked 
perc-contaminated drinking water to increases in leukemia in an exposed population cohort and to increased 
urinary, bladder, and esophageal cancers in perc-exposed dry-cleaning workers. Other perc-related cancers 
include cervical cancer and non-Hodgkin's lymphoma. Because of these data. Huff believes occupational 
exposures to perc do present a hazard. 

Robin Hill, a risk manager at Health Canada, says, that Canadian health authorities disagree with IARC, and 
don’t think the evidence is strong enough to label perc a human carcinogen. Even so, cutting back on perc 
seems to be a widely accepted goal, even in Canada. The Ontario government has already proposed reducing 
workplace exposure from 50 pans per million (ppm) during an 8-hour workday to 10 ppm. 

While current regulations of the Occupational Safety and Health Admini-stration (OSHA) limit worker 
exposure to 100 ppm, the agency is examining evidence to see if the standard should be changed. "There is a 
long-standing relationship between the agency [OSHA], the dry-cleaning industry, and public interest groups 
aimed at reducing exposure," says Joseph Cotruvo, who oversees chemical screening and risk assessment at 
the EPA's Office of Pollution Prevention and Toxics. 

The U.S. dry-cleaning industry, which employs more than 250,000 people, has taken steps to cut back on 
perc usage. "Perchloroethylene use in 1988 was approximately 250 million pounds in the U.S.; in 1994 it was 
150 million pounds," says Mary Scalco, director of government relations for the International Fabricate 
Institute (IFI), the dry-cleaning trade association. She says improved technology is the primary reason for the 
decrease. And attempts to develop alternate methods in dry-cleaning are being explored with the support of 
several agencies, including the EPA, and industry. 

Liquid C02 

One technology being investigated uses liquid carbon dioxide (C02) as a dry-cleaning solvent. Hughes 
Environmental Systems of El Segundo, California, has developed a prototype dry-cleaning machine and 
process called DryWash. The system, which uses liquid C02, was exhibited in Milan at an international 
dry-cleaning exposition in March. While the EPA’s Design for the Environment program hasnot funded 
research on liquid C02, it has held conferences and encouraged the exchange of information about its 
potential. 

Sid Chao, president of Hughes Environmental Systems, says liquid C02 doesn’t have the environmental and 
health drawbacks of perc. OSHA limits exposure of C02 to 5,000 ppm for an 8-hour day. 










tests indicate that it is better than the perc process." 


Besides performance, other questions remain about how a liquid C02-based system would fit into the 
operations of the approximately 30,000 dry-cleaning establishments in the United States. 

Cost is one crucial concern for dry-cleaners. "Commercial dry-cleaning is not a high-profit business, and many 
dry-cleaners are barely able to stay in business," states a 1995 EPA profile of the trade. Acording to the EPA 
report, the cost to start up a dry cleaning business in 1993 was $113,000. 

Scalco says that she’s seen no information on the cost of liquid C02 machines from Hughes, but "for liquid 
C02 [to be a viable option] you have to have equipment that's affordable. That's probably the biggest thing 
right now." 

"Can we provide a system where the unit costs per pound for producing a clean garment are comparable [with 
existing technology]?" wonders Wentz. He notes that liquid C02 may have some economic factors in its favor. 
The shorter cleaning cycle means more garments can be cleaned in less time. Furthermore, labor costs for 
finishing or pressing the garments may be reduced, since the garments are cleaned at lower temperatures, 
which reduces wrinkling. Such factors will help determine if the liquid C02 process will fit within the present 
dry-cleaning infrastructure, says Wentz. 

If the DryWash machines prove too costly for individual "mom and pop" dry-cleaners (which make up most of 
the dry-cleaning operations in the United States, according to the EPA), the machines may find homes in 
central facilities, with customers dropping their clothes off at storefronts or so-called "dry stores" to be taken to 
the central facilities for cleaning. This is already a trend in dry-cleaning, says Scalco. But this system may 
negate some of liquid C02's potential environmental advantage by causing increased fuel consumption and 
pollution from transporting the clothes, Wentz cautions. A life-cycle study of factors such as these would have 
to be done to assess the advantage of liquid C02 from an environmental perspective. 

Wet-cleaning 

Wet-cleaning is another method being examined to replace perc. Highly touted by the environmental activist 
group Greenpeace, this European-developed method uses water and specially designed soaps instead of 
solvents to clean clothes. 

The machines that do the cleaning are sophisticated washers and dryers in which humidity, agitation, and heat 
are computer controlled. "By controlling all those factors in a better way, it's possible to clean clothes with 
water that used to be dry-cleaned," says Jack Weinberg, a campaigner against toxic chemicals for Greenpeace. 

Wet-cleaning, or wet wash as it is sometimes known, is used in Germany and Austria and has also been tried 
on a demonstration basis in the United States and Canada. 

With funding from the EPA, Greenpeace, and the Center for Neighborhood Technology (CNT) in Chicago 
have been examining how well wet-cleaning cleans clothes in a study with the Greener Cleaner, a private 
dry-cleaning business that has been operating since May 1995. The study is part of an agreement between 
Greenpeace, the CNT, and the IFI to assess perc alternatives. 

Jo Patton, CNT project director for the wet-cleaning demonstration, says the wet-cleaner has successfully 
cleaned virtually all garments brought to it, rejecting only about one-tenth of a percent because tests at the store 
showed that dyes would run. She says wet-cleaning has been able to clean clothing made of wool, silk, rayon, 
cotton, and blends of fabrics. Weinberg claims that even leather can be wet-cleaned satisfactorily. 

In Canada, a wet-cleaning demonstration project begun in 1994 and funded in part by the government reported 
that 30-80% of garments currently dry-cleaned can be satisfactorily wet-cleaned, a figure far greater than the 
3-15% of clothes (excluding shirts) now cleaned in water at dry-cleaners. A report on the project, which 
involved six cleaning facilities, concluded, however, that wet-cleaning "does not appear to be a complete 


Global Technologies, LLC 


Global Technologies, LLC, is a technology management company created to 
commercialize technologies such as DryWash™ coming out of the aerospace industry. 
We are jointly owned by Itochu Aviation, part of global trading company Itochu Corp., 
and Anscott Chemical Industries, services laundry, drycleaning, and garment industry. 


Hughes Environmental Systems, Inc. (HESI) 

Hughes Environmental Systems, Inc. (HESI), was incorporated in 1989 as a wholly 
owned subsidiary of Hughes Aircraft Company. HESI has two missions: 

1. To provide Environmental, Health, & Safety Services to Hughes Electronic. 

2. To commercialize appropriate Hughes technologies in order to realize dual use of 
technologies that began with military applications. 

HESI’s strategy to fulfill the second, key, mission is to identify a market need, match the 
need to an appropriate Hughes-owned technology, and then follow a rigorous due 
diligence process of evaluation, partner selection, and technology validation. HESI 
concurrently develops that technology for the market application while forming alliances 
(partnerships, licensing agreements, etc.) with companies who are experienced in 
productizing, marketing, and distribution in the targeted industry. 

HESI team members have had success with a number of ventures including DryWash™, 
C0 2 textile cleaning; SuperScrub™ precision cleaning; and HF1189™ solder flux. 









L os Alamos National Laboratory is 
one of the largest multidisciplinary, 
multiprogram laboratories in the world. 
Situated on more than 43 square miles in 
northern New Mexico, the Laboratory has 
6700 regular full-time employees and an 
approximate FY97 budget of $1 billion. 

We are operated by the University of California 
for the Department of Energy and are one 
of the Department’s nine multiprogram 
national laboratories. 

Over our 50-year history, our primary mission 
has been to apply science and technology to 
problems of national security. Well before the 
end of the Cold War, however, this mission 
was expanded to include addressing energy, 
economic competitiveness, and other national 
problems. In support of this broad mission, 
we conduct basic and applied research in 
hundreds of areas ranging from advanced 
manufacturing techniques to human genome 
studies, from alternative energy sources to 
new polymers. Four key areas of expertise and 
resources are expanded upon below. A vital 
facet to all our work is R&D collaboration with 
private industry. 

Chemistry and Materials Science. In a far- 
reaching materials science and technology 
program, we conduct research in metallurgy 
and ceramics, high-temperature superconduc¬ 
tivity, materials chemistry, and condensed- 
matter physics. We have contributed to the 
development of advanced high-strength alloys 
and composite materials and to advances in 
manufacturing processes like high-energy 
welding and near-net shape fabrication 
techniques. Our special strengths are the 
availability of multidisciplinary research teams 
and the accessibility of integrated capabilities 
for the design, prototyping, analysis, and 
testing of new materials. 


Advanced Computing and Modeling. 

Los Alamos has always been on the frontier 
of computational science and has driven 
developments in the computer industry. 

We have one of the world’s most advanced 
computer networks, with the combined 
computing power of about 75 CRAY-1 
machines. To complement this computing 
muscle, we have a multidisciplinary staff 
skilled in developing and applying complex, 
versatile algorithms to real-world problems. 
The upshot is an ability to model and simulate 
a wide range of processes important 
to industry. 

Biotechnology. Our mission is to address bio¬ 
logical problems at the molecular, cellular, and 
whole-organism levels. We have pioneered in 
such areas as developing flow cytometry and 
applying accelerator-related technology to 
improve biomedical techniques, instruments, 
and models. We have programs under way to 
understand how radiation and chemicals affect 
human health and to study the structure and 
dynamics of biological macromolecules. The 
Laboratory is also one of three Department of 
Energy Centers for Human Genome Studies. 

Environmental R&D. We have a broad 
environmental R&D effort that encompasses 
site characterization and remediation, waste 
minimization, and environmentally conscious 
manufacturing. We have developed advanced 
lasers to detect and track air pollutants, 
computer codes to forecast the direction and 
speed of pollutant transport, technologies to 
isolate and extract metals and other toxic 
materials from waste streams, environ¬ 
mentally benign industrial solvents, and 
manufacturing techniques that incorporate 
environmental safeguards from design 
through product lifetime. 


Los Alamos 

NATIONAL LABORATORY 


A US DEPARTMENT OF ENERGY LABORATORY 

January 1997 • Los Alamos National Laboratory, an affirmative action/equal opportunity employer, 
is operated by the University of California for the US Department of Energy under contract W-7405-ENG-36. 










Surfactant Research for C0 2 Processes 


Jim McClain, Ph.D. 

MiCELL Technologies 

Dr. Jim McClain is one of the co-founders of MICELL ™ Technologies, Inc. He 
currently serves as the Director of Research, Development, and Engineering where he is 
responsible for technical leadership and overall coordination of the development of active 
chemistry, formulations, process research and development, system engineering, and 
mechanical build-up and engineering. 


Thanks. I appreciate the opportunity to talk in front of this audience and also the fortitude of this 
audience to still be here at this point in the day. 

I'm going to take a pretty big change in the slant of my presentation. I'll cover all of the benefits 
of C0 2 and C0 2 based technology, C0 2 as a replacement for drycleaning as well as other solvents and 
water based technologies. I believe in those items, and I wholly support all the advantages and everything 
that Craig and all the other speakers on the C0 2 field have gone over. 

What I will do that is different is to try to get into how can we make detergents for carbon 
dioxide. I have been involved in the study of C0 2 , and specifically the design and characterization of 
surfactants for C0 2 , for about the last five years. My work started out with Joe DeSimone at UNC, where 
my work culminated at about the same time as the green chemistry award; that is probably a coincidence. 
Then I moved on to MiCELL, where I have been trying to take these surfactant developments and turn 
them into a commercial reality. 

The key to operating and designing a surfactant for C0 2 is not so much in finding something that 
dissolves or finding something that forms a micelle. The key is integrating it into a cleaning process so it 
can get the job done, so it can provide clothes that are clean and in a state ready for finishing. It should be 
in a state acceptable to both the professional drycleaner and the customer. 

I don't profess to be a drycleaner, but I have had the opportunity to work with and get advice from 
a lot of the best professionals in this field. The first time I ever met Manfred Wentz, he told me, "just 
because you've got something that dissolves or just because you've got a micelle, doesn't mean you have a 
good cleaning system. What you have really got to do to develop a good cleaning system is, you have to 
get dirt off a substrate. Nobody really cares how you do it or how pretty your chemistry is, or how 
beautiful your machine is. You have to get an unfavorable soil into the fluid and the fluid taken away." 

In C0 2 , that means it either has to dissolve in the fluid, be removed by agitation and taken out of 
the system, or carried into the fluid by some kind of surfactant, detergent, soap, micelle. 

This slide shows a schematic of a basic C0 2 cleaning process. This has been touched on in some 
of the other talks today. The surfactant can pull the dirt up off the substrate and into the solution in the 
micelles. The fact that the core region in these micelles is water is one of the most important parameters 
for good drycleaning. I have been tutored and have tried to listen time and time again, to the fact that 
moisture is the key to getting effective detergency. A large part of a tremendous body of research has 


101 










been trying to get free water micro-emulsions or emulsions into a C0 2 environment to effect removal of 
polar stains. 

We have hit upon the physical properties of C0 2 and what makes it different. What I want to 
touch on just for a second is how these properties influence the design of surfactants for C0 2 . 

Carbon dioxide is a very gentle solvent in the liquid state. There have been studies that prove its 
excellent effect on the garments, its effects on fibers, finishes and what have you. However, it is a very 
good solvent for drycleaning. It is a very challenging solvent to try to build soap for, because it has a 
tremendously low viscosity and an extremely low dielectric constant. The dielectric constant is the 
parameter that we like to use as opposed to a KB value or a solubility parameter. We are down here in 
the region that is really analogous to fluonnated solvents with its ability to stabilize a polar system, and 
petroleum and perc are better in that order. 

What this means is that C0 2 can only dissolve a select few materials in the readily available 
liquid state, around ambient or slightly sub-ambient conditions. This is essentially high vapor pressure 
fluids. Basically anything that you could pour into a glass, except water, dissolves m C0 2 fairly readily. 

Soon hydrocarbon monomers, were explained in talks by Joe DeSimone, where we worked very 
hard on polymerization processes. Then as far as high molecular weight materials that can provide you 
building blocks for a surfactant, we are limited to the lowest surface energy materials available. They are 
the siloxane polymers and the amorphous fluonnated materials. 

In this slide, insoluble in C0 2 is summarized best by the first line. It is very hard to get plastics, 
heavy oils, heavy greases to dissolve in C0 2 when you get into higher loadings of grease, and heavy 
stains, and the things that we care about in drycleaning. They are very hard to get to dissolve, because 
they are highly polar substances; water being the key that has a very low solubility in C0 2 , and almost all 
of their polymeric building blocks. 

What we are able to do is take advantage of the solubility of polymers in carbon dioxide and 
classify them two different ways. We have a C0 2 philic classification, and a C0 2 phobic classification. 

Under C0 2 philic, we can divide the world into traditional hydrophilic materials, these are water 
loving materials that have the potential to dissolve or be swollen by water, as well as oil soluble materials, 
like polystyrene or poly methylmethacrolate, your traditional plastics. This is one of the things that 
makes us able to clean textile fibers in C0 2 , because these materials are not significantly swollen or 
dissolved by carbon dioxide. But it also means that we have a field of surfactant design that includes both 
oil based materials and water based materials to get the most effective detergent action in carbon dioxide. 

What we wanted to build are surfactants based on a combination of a C0 2 phile and a C0 2 phobe. 
A lot of this technology and terminology has been published in the literature. But through design of this 
structure of a C0 2 loving and a C0 2 hating material which are logically designed for a C0 2 system, we 
can build detergents that are active in carbon dioxide. Then, we can build processes around these 
detergents that put them to work to actually get the job of drycleaning done. 

The picture of the kind of surfactant and detergent we are trying to build is best done in the balls 
and swiggles methodology that we have seen a few times. But, in traditional water systems, you build a 
micelle. You do this every time you do the dishes or you wash your clothes in water or you wash your 


102 


hands in the restroom. You build a micelle to carry the oils and greases into the water phase. The oils 
and greases don't want to be in the water phase; they need to be carried there by a specific amphophilic 
molecule. The molecule is able to pull an oil phase into the center of its domain and act on soils not 
otherwise soluble in the continuous phase. 

The exact same idea drives the design of surfactants for C0 2 , except that we have to get very 
creative. Here you see these PFOA and PEO. PFAO stands for a fluonnated acrylate material. It is one 
of the amorphous fluoropolymer chemicals that is soluble in C0 2 that we can use to design the corona of 
a micellar structure to dnve and pull water into carbon dioxide. 

The next task is how to make this water core act as a detergent. It is one goal to be able to build a 
micelle, it is another goal to be able to make it work. The best example published of making micelles go 
to work is a paper that came out in Nature in 1997 that was a massively collaborative effort with the 
University of California, University of North Carolina, Oak Ridge National Labs and others. 

Essentially, we made a surfactant out of one molecule. We made what is called a dendromer. It 
is a C0 2 based surfactant, and it proved the concept that we could take a C0 2 philic exterior and a C0 2 
phobic hydrophilic interior and make it act on a water phase. The colored pictures on the right of this 
slide show that as we go from A to D, this is a C0 2 phase sitting on top of a water phase. In the 
beginning, we have dye dissolved in the water. Toward the end, you can see that the dye has been pulled 
out of the water phase and trapped into the C0 2 . 

We made a micelle, and then we made it go to work. We made it pull this material out of the 
water and into itself. That is a great start, but we need to make these things act on a surface. That has 
been a lot of the work that has gone on at MiCELL. 

The next part of the structure that can be developed is the design and application of surfactants. 
We took this to a slightly higher level, in that we actually measured them. We built a surfactant micelle 
in C0 2 , and measured its characteristics with neutron scattering. With this information we can start to 
build micelles; we can start to put them together, we can start to take them apart. We can start to do 
things that take care of one of the problems that Craig brought up. When you add a surfactant to a 
system, you are essentially adding to your dirt in a traditional system. 

What you can do in a C0 2 based system, through proper tailoring of a surfactant, is to cause it to 
open up and release its dirt. This is under development still in academic labs with Professor di Simone. 
However, it is a concept that has the ability to change the pressure of C0 2 , the ability to change its 
solubility characteristics, and we can open up this window. This feels like science fiction. You make 
your soap go over here, go to work, you bring it over here and you drop your dirt and you send it back. It 
will never be 100 percent. It will never function just like that, but it is something that is possible in C0 2 
that is next to impossible in any other kind of fluid. 

I want to shift gears for one or two minutes here and bring up another topic that we hit on. 

Having soaps that work is the first step, integrating them into a process that cleans clothes is the second 
step. With the MiCARE process that Brad Lienhart alluded to and described a bit earlier today, we follow 
a similar drive towards simplicity. Ours is a rotating basket design. We can get into the details and 
differences between DryWash and MiCARE for the rest of the year. 


103 


Essentially, we integrate our detergents into the system in such a way that they act on the clothes 
and can be removed and separated from the contaminants. It is essentially a traditional system, except 
that now, the fluid used instead of perc and detergent is C0 2 and detergent. We have designed the 
systems to work in almost exactly the same manner. I've been tutored by drycleaners like Williams 
Cleaners and Buster Bell, and I ask drycleaners a lot of questions. I want to find out what we can do to 
make the transition of operation to a new system as painless as possible. We want to know how best to 
change from a very common solvent such as a liquid solvent such as petroleum or a chlorinated material 
to something that is really unique, a densified version of the same gas we are all exhaling into this room. 
We want to keep the system as close to optimum as possible. 

We have tested the compatibility of the C0 2 and the C0 2 with our additives. I could make a very 
long story out of the short answer, that it works fine, much like the additives in a typical perc or 
petroleum machine. However, it is not so much a problem with the additives, it is a problem with what 
you do with them. If you go home and dump a half gallon of water into this system, you’re going to 
damage acetate and you're going to shrink some woolens, but under normal operation and normal kinds of 
controls, it will work just like another soap and solvent system. 

We have looked into—with the assistance of some friends in the College of Textiles at NC 
State—the comparability with real small sampling of dyed fabrics with much the same result and the 
same story. We haven't and we won't look at every dye in the world, but all the dyes that we were able to 
come up with showed very little change before and after exposure to our chemistry. 

We have also embarked on a study of buttons and finishes and other related issues. These are on 
display fairly regularly, as well as on our website; you can get more information on the computability 
with everything that we have looked at. 

The same cleaning challenges hold true with leather and suede. We have embarked on the ability 
to both treat, clean and fix up leather and suede. 

I'll leave this presentation on something positive. That is, if we can get a detergent additive into 
C0 2 , get it to pick up water, and act like a detergent additive and like a detergent solvent system that we 
are all used to with perc and petroleum, then we can make these things clean exceptionally well. 

This is an old slide where we were comparing C0 2 with perc performance from a local 
drycleaner. I have no intention of showing people that clean with perc how well they do or don't do. I 
will rather focus on our cleaning performance versus the untreated stain. We are able to remove the broad 
gamut of stains without pretreating, and using a room temperature process. We give our system a chance 
to do its best on a stain or on the fabnc, and then if necessary, there is the option for post treatment 
without any heat setting. 

There is a lot of this performance data across the range of stains. This slide shows blueberry 
juice, and there is a spaghetti sauce version on different fabrics. The addition of water gives you an acidic 
system that acts to our benefit in removing stains. The production of isolated domains of water of a 
typical micro emulsion surfactant in a solvent system allows a very high performance level of cleaning in 
a traditional manner. 

I thank you for your attention. 


104 


Changing the Care Labeling Rule to Fit Changing Times 


Connie Vecellio 
Federal Trade Commission 

Connie Vecellio is currently an attorney in the Division of Enforcement of the Bureau of 
Consumer Protection at the Federal Trade Commission, where she has served since 1977. 
For the last several years her responsibilities have included enforcing the Commission’s 
Care Labeling Rule, which requires care labels on textile wearing apparel. 


I am happy to be here today to speak at this very forward-looking conference, and I am very 
happy to speak to you on this particular day because something happened yesterday that I can tell you 
about. 


The Federal Trade Commission voted to issue a notice of proposed rulemaking to make some 
changes in the Care Labeling Rule that we talked about in the January workshops and previously in the 
conference in September 1996, sponsored by EPA. The notice has not been published in the Federal 
Register yet. It is hot off the press, as Mary Ellen said. You have copies of it at your desks. You are all 
getting advance notice of this. 

My remarks today are strictly my own opinions and don't necessarily represent the opinions of the 
five commissioners. That is another reason the notice is so valuable. Because it does represent the 
opinions of the five commissioners. They all voted for it and they are voting to move forward with the 
Rule. 


So, today, I am first going to discuss with you the proposed changes in the Rule. Secondly, I 
want to discuss a proposal that I have for gathering more data about problem garments, garments that are 
damaged when dry cleaned. Based on what I have heard here the last two days, I believe that a large 
database of problem garments would be a great help to the goals that we are trying to achieve and the 
goals that were brought up in the January workshops. But, first, I want to talk to you about the largely 
EPA-inspired changes in the Care Labeling Rule and I am going to move over here and start using my 
slides. 


In 1994, as part of its ongoing review of all its Rules, the Commission published a notice asking 
about the usefulness of the Care Labeling Rule. The general response was that it is very useful and it is 
one of our most popular Rules. But that 1994 notice did note that EPA had designated perchloroethylene, 
or perc, as a hazardous air pollutant under Section 112 of the Clean Air Act and that EPA had been 
working with the drycleaning industry to reduce exposure to perc. That led to proposed revisions in the 
Rule, which the Commission published in November 1995. 

The revision of most interest to everybody here today, I think, was a proposal that the Rule be 
changed to allow for labeling for professional wet cleaning. Secondly, though, and also relevant to the 
goals of reducing exposure to perc, is the proposal to change the Rule to require that any garment that 
could be laundered at home be labeled for laundering at home. 


105 



The Rule currently requires a washing instruction or a drycleaning instruction, but does not 
require both. Some garments labeled "dryclean" could be washed at home, but the consumer can't be 
certain that is true. The Commission asked for comment on both of these issues. 

When I talked in 1996 at the EPA conference, I spoke about professional wet cleaning and the 
fact that we would need a definition of professional wet cleaning before we could allow garments to be 
labeled for professional wet cleaning. I want to remind you that the Rule defines "drycleaning" very 
specifically - that is, as a commercial process by which soil is removed from products or specimens in a 
machine which uses any common organic solvent—for example, petroleum, perchloroethylene or 
fluorocarbon. The process may also include adding moisture to the solvent up to 75 degrees relative 
humidity, hot tumble drying up to 160 degrees Fahrenheit, and restoration by steam press or steam air 
finishing. (Now, some of you are going to be noting, by the way, that we are probably going to have to 
change that definition to delete fluorocarbon. We may also need to add some of the new solvents, like 
liquid carbon dioxide and Rynex, but that is in the future.) 

The purpose of the definition is to ensure that when a label says a garment can be drycleaned, the 
garment is able to withstand a clearly-defined process without damage. Because the process is defined, 
the manufacturer who labels a garment and the cleaner who cleans it are talking about the same process. 
A manufacturer who wishes to label a garment "dryclean" can subject sample garments to the defined 
process, and, if they survive the process without damage, the manufacturer will have a reasonable basis 
for labeling them "dryclean." The Rule also provides that the manufacturer must put a warning on the 
label if any part of the process must be modified, in order for the garment to be drycleaned without 
damage. For example, if the garment would be damaged by hot tumble drying at 160 degrees Fahrenheit 
but can withstand the drycleanmg process with low heat, the garment can be labeled "dryclean, low heat." 

In order to include professional wet cleaning in the Rule we need a standardized definition for 
professional wet cleaning similar to what we have for drycleaning so that manufacturers will know 
precisely what is meant by "professional wet cleaning" and will be able to determine if their garments can 
withstand that process without damage. The Rule requires that manufacturers have a "reasonable basis" 
for the care instruction they place on their garments. If there is a standardized definition of professionally 
wet cleaning, a manufacturer could subject sample garments to that process, and, if they survive without 
damage, the manufacturer would have a reasonable basis for labeling them for professional wet cleaning. 

We also need a standardized definition so that garments that cannot withstand the process as 
defined but could withstand the process with certain modifications can be labeled for professional wet 
cleaning. That is, such garments could be labeled for professional wet cleaning with appropriate 
warnings about specifically how the professional wet cleaning process should be modified so that those 
garments can be professionally wet cleaned without damage. 

Let me show you the definition for professional wet cleaning contained in our notice of proposed 
rulemaking. 

Professional wet cleaning means a system of cleaning by means of equipment consisting of a 
computer-controlled washer and dryer, wet cleaning software, and biodegradable chemicals specifically 
formulated to safely wet clean wool, silk, rayon, and other natural and man-made fibers. The washer uses 
a frequency-controlled motor, which allows the computer to control precisely the degree of mechanical 
action imposed on the garments by the wet cleaning process. The computer also controls time, fluid 
levels, temperatures, extraction, chemical injection, drum rotation, and extraction parameters. The dryer 


106 


incorporates a residual moisture (or humidity) control to prevent overdrying of delicate garments. The 
wet cleaning chemicals are formulated from constituent chemicals on the EPA's public inventory of 
approved chemicals pursuant to the Toxic Substances Control Act. 

Now, please feel free to attack this definition and improve it. We just wanted to get the ball 
rolling. We proposed defining it as a system of cleaning by means of specific equipment, as you can see. 
And with the use of chemicals on EPA's public inventory of approved chemicals. 

Now, back to the requirement that a manufacturer have a "reasonable basis" for its care 
instructions. A reasonable basis under the Rule may be tests showing that the garment can be cleaned as 
directed on the label. It may be technical literature indicating that the garment can be cleaned as directed. 
It may be past experience or industry expertise. But, of course, in the case of professional wet cleaning, 
past experience is almost non-existent, so testing becomes more important. But there are currently no 
standardized tests for professional wet cleaning. So what can a manufacturer do, given the definition that 
we proposed here, to have a reasonable basis for a label that recommends professional wet cleaning? He 
or she can have sample garments cleaned in equipment similar to that defined in the Rule. And if they 
survive, that can constitute a reasonable basis for the label. 

If instead we have a very general definition of professional wet cleaning of the kind that has been 
proposed - for example, "clean in water" - what could the garment manufacturer do to have a reasonable 
basis for labeling garments for professional wet cleaning? Let's say a manufacturer has made a wool suit 
that would survive professional wet cleaning in the type of equipment we have described with no damage, 
and he wants to label it for professional wet cleaning. But if professional wet cleaning simply means 
"clean in water," he would have to have a reasonable basis for saying it could be cleaned in water by any 
available method, including simply washing it in a home washing machine. And most wool suits would 
not survive washing in a home washing machine. Therefore, under that definition, the suit could not be 
labeled "professionally wet clean." If the goal is to allow garments that cannot be currently be labeled 
for home washing - either by hand or by machine - to be labeled for cleaning in water, we need a precise 
definition of the process by which those garments can be cleaned. And we need that precise definition for 
two reasons. First, to make clear that the garments cannot be washed in a home washer or hand washed at 
home. Second, we have to define the process clearly to make sure that the manufacturer who labels the 
garment for wet cleaning and the person who cleans the garment are talking about the same thing when 
they say "professionally wet clean." 

Now, back to the new Commission notice of proposed rulemaking. It proposes a very specific 
definition for professional wet cleaning, and it says that if a "professionally wet clean" instruction is 
included, it must state at least one type of equipment that can be used, unless all types of equipment can 
be used. Again, I really encourage you to comment on these issues. We are just trying to get the ball 
rolling. This may not be what is needed, but I want to stimulate some comment and ideas on that. 

The notice also proposes that, if a care label recommends professional wet cleaning, the fiber type 
must be included on that care label. We proposed this because a number of comments we already 
received indicate that fiber type is particularly important in professional wet cleaning, and currently fiber 
type can be on a separate label that can be cut off. Thus, the proposed Rule requires that the permanent 
care label have the fiber content if professional wet cleaning is recommended. 


107 






You should also notice that while the proposed Rule allows professional wet cleaning to be 
recommended on the care label, it requires that another type of cleaning must also be recommended, 
either washing or drycleaning. Now, the reason for that is the limited availability of professional wet 
cleaning to consumers. From the evidence we had on the record from the last round of comments, it 
appeared that there were large areas of the country in which there were no professional wet cleaners so 
that consumers in those areas would not really have that option. But this notice seeks comment again 
with regard to how many wet cleaners there are and where they are. I certainly encourage you to give us 
that information. If the number is growing by leaps and bounds and the option is available widely around 
the country, the requirement could probably be removed. 

Now I'd like to take just a few minutes to discuss a proposal that I have for gathering more data 
about garments that are damaged when cleaned. The goal is to establish a large database on the safety 
and effectiveness of the various cleaning methods for vanous types of textiles and garments, both new 
and old cleaning techniques. Thus far, there is only one such computerized database available and it is 
maintained by the International Fabncare Institute, IFI. They have been computerizing a portion of their 
data for more than ten years. It is an expensive process, and they don't computerize all the garments they 
analyze. 


But they have also always asserted that their data is just the tip of the iceberg, that is, of the total 
number of garments that are damaged in cleaning. So, what we are trying to do is get a view of more of 
the iceberg. Then that data would help manufacturers to label and to make a more rational decision about 
what care instructions to put on their garments. It could also help cleaners to become aware of what types 
of garments are particularly prone to certain problems. The data might also identify problem cleaners and 
problem garments, and trade associations might use that data to identify cleaners who may need or want 
more training. 

Let me just quickly talk about this plan for getting more data because I do hope we can talk about 
that later in our breakout workgroups. One idea is to create a method for an electronic filing of 
complaints; and the FTC might be able to create an electronic form. A paper form could also be used but 
would probably take more time to process. 

Another issue involves where the should data be sent. Should the FTC be the only recipient? 
Should it be sent to a third party, such as the American Apparel Manufacturers Association, which could 
sort it and forward it to the manufacturers involved, or should it be sent to a third party for analysis, such 
as a university professor and/or students? There are advantages and disadvantages for each possible 
recipient. The FTC would use the data to investigate and bring cases, where appropriate. We could 
share it with EPA. We could provide it to the experts, who are currently evaluating the effectiveness of 
cleaning methods. 

The American Apparel Manufacturers Association (AAMA) could evaluate the data in terms of 
the combinations of trim, fabric, et cetera, which have been damaged and pass that information along to 
its members. The firms who have a high number of complaints could use it to take corrective action. 

Now, another idea for getting more data is to help IFI, the Neighborhood Cleaners Association, 
and also state associations. These entities may separately be gathering data and may be willing to 
computerize all their data. We have the same issues about where that gathered information should go and 
the pros and cons of sending it to the various sources. 


108 


A third possible source of data is the Better Business Bureaus, which get many 
complaints—disputes between drycleaners and their customers. We could work with them to computerize 
that data and add that to our source. 

Finally, we could help small claims courts, which also get a lot of these disputes, computerize 
their data and we could add that to our source. 

I will stop there and we can, hopefully, discuss this further in the breakout sessions. 


109 







Proposed Rules 


Federal Register 

Vol. 63, No. 89 
Friday, May 8, 1998 


25417 


This section of the FEDERAL REGISTER 
contains notices to the public of the proposed 
issuance of rules and regulations. The 
purpose of these notices is to give interested 
persons an opportunity to participate in the 
rule making prior to the adoption of the final 
rules. 

FEDERAL TRADE COMMISSION 

16CFR Part 423 

Trade Regulation Rule on Care 
Labeling of Textile Wearing Apparel 
and Certain Piece Goods 

AGENCY: Federal Trade Commission. 
ACTION: Notice of proposed rulemaking. 

SUMMARY: The Federal Trade 
Commission (the “Commission”) is 
commencing a rulemaking to amend its 
Trade Regulation Rule on Care Labeling 
of Textile Wearing Apparel and Certain 
Piece Goods, 16 CFR Part 423 (“the Care 
Labeling Rule” or “the Rule”). The 
Commission proposes amending the 
Rule: (1) To require that an item that can 
be cleaned by home washing be labeled 
with instructions for home washing: (2) 
to allow that a garment that can be 
professionally wet cleaned be labeled 
with instructions for professional wet 
cleaning; (3) to clarify what can 
constitute a reasonable basis for care 
instructions; and (4) to change the 
definitions of cold, warm, and hot water 
in the Rule. The Commission is 
commencing this rulemaking because of 
the comments filed in response to its 
Advanced Notice of Proposed 
Rulemaking (“ANPR”), and other 
information discussed in this notice. 

The Commission invites interested 
parties to submit written data, views, 
and arguments. This notice includes a 
description of the procedures to be 
followed, an invitation to submit 
written comments, a list of questions 
and issues upon which the Commission 
particularly desires comments, and a 
description of a workshop conference 
that will be held to discuss the issues. 
The Commission will announce the 
time and place of the public workshop 
after the close of the comment period. 
Any persons wishing to participate in 
the public workshop must file a 
comment in response to this notice and 
must indicate therein their interest in 
participating. The comments will be 
available on the public record and on 
the Commission’s web site on the 


Internet (http://www.ftc.gov) so that 
interested parties can review them. 

After the conclusion of the workshop, 
the record will remain open for 30 days 
for additional or rebuttal comments. If 
necessary, the Commission will also 
hold hearings with cross-examination 
and rebuttal submissions, as specified in 
Section 18(c) of the Federal Trade 
Commission Act, 15 U.S.C. 57a(c). 
Interested parties who wish to request 
such hearings should file a comment in 
response to this notice and indicate 
therein why they believe such hearings 
are necessary and how they would 
participate in such hearings. 

DATES: Written comments must be 
submitted on or before July 27,1998. 

ADDRESSES: Written comments should 
be identified as “16 CFR Part 423—Care 
Labeling Rule—Comment,” and sent to 
Secretary, Federal Trade Commission, 
Sixth and Pennsylvania Ave., N.W., 
Washington D.C. 20580. To facilitate 
prompt and efficient review and 
dissemination of the comments to the 
public, all written comments should 
also be submitted, if possible, in 
electronic form, on either a 5V« or a 3Vi 
inch computer disk, with a label on the 
disk stating the name of the commenter 
and the name and version of the word 
processing program used to create the 
document. Programs based on DOS are 
preferred. In order for files from other 
operating systems to be accepted, they 
should be submitted in ASCII text 
format. 

FOR FURTHER INFORMATION CONTACT: 

Constance M. Vecellio or James Mills, 
Attorneys, Federal Trade Commission, 
Division of Enforcement, Bureau of 
Consumer Protection, Sixth St. and 
Pennsylvania Ave., N.W., S—4302, 
Washington. D.C. 20580, (202) 326-2966 
or (202) 326-3035. 

SUPPLEMENTARY INFORMATION: 

Part A—Introduction 

This notice is being published 
pursuant to Section 18 of the Federal 
Trade Commission (“FTC”) Act, 15 
U.S.C. 57a et seq., the provisions of Part 
1, Subpart B of the Commission’s Rules 
of Practice, 16 CFR 1.7, and 5 U.S.C. 551 
et seq. This authority permits the 
Commission to promulgate, modify, and 
repeal trade regulation rules that define 
with specificity acts or practices that are 
unfair or deceptive in or affecting 
commerce wi thin the meaning of 


Section 5(a)(1) of the FTC Act, 15 U.S.C. 
45(a)(1). 

The Care Labeling Rule was 
promulgated by the Commission on 
December 16, 1971, 36 FR 23883 (1971). 
In 1983, the Commission amended the 
Rule to clarify its requirements by 
identifying in greater detail the washing 
or dry cleaning information to be 
included on care labels. 48 FR 22733 
(1983). The Care Labeling Rule, as 
amended, requires manufacturers and 
importers of textile wearing apparel and 
certain piece goods to attaci care labels 
to these items stating “what regular care 
is needed for the ordinary use of the 
product.” (16 CFR 423.6(a) and (b)). The 
Rule also requires that the manufacturer 
or importer possess, prior to sale, a 
reasonable basis for the care 
instructions. (16 CFR 423.6(c)). 

As part of its continuing review of its 
trade regulation rules to determine their 
current effectiveness and impact, the 
Commission published a Federal 
Register notice (“FRN”) on June 15, 
1994, 59 FR 30733. This FRN sought 
comment on the costs and benefits of 
the Rule, and related questions such as 
what changes in the Rule would 
increase the benefits of the Rule to 
purchasers and how those changes 
would affect the costs the Rule imposes 
on firms subject to its requirements. The 
comments in response to the 1994 FRN 
generally expressed continuing support 
for the Rule, stating that correct care 
instructions benefit consumers by 
extending the useful life of the garment, 
by helping the consumer maximize the 
appearance of the garment, and/or by 
allowing the consumer to take the ease 
and cost of care into consideration when 
making a purchase. 

Based on this review, the Commission 
determined to retain the Rule, but to 
seek additional comment on possible 
amendments to the Rule. The 
Commission published an ANPR on 
December 28,1995, 60 FR 67102, which 
elicited 64 comments on the several 
possible amendments of the Rule 
described^he^ein. , Based on the 


1 The comments were from; 41 consumers; one 
consumer group; four academics; one clothing 
retailer; one textile manufacturers association; one 
apparel manufacturers association; one professional 
cleaner; one professional cleaners association; one 
wet cleaning equipment manufacturer, two 
manufacturers of cleaning products; one cleaning 
products manufacturers association; one 
environmental protection group; one non-profit 

Continued 









25418 


Federal Register /Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


comments and the evidence discussed 
herein, the Commission proposes to 
amend the Rule in the following ways. 

Part B—Analysis of Proposed 
Amendments 

1. Labeling for Home washing 

a. Background and Discussion of 
Comments 

The 1994 FRN noted that the 
Environmental Protection Agency 
(“EPA”) had been working with the dry 
cleaning industry to reduce the public’s 
exposure to perchloroethylene (“PCE” 
or “perc”), the most common dry 
cleaning solvent, * 2 and asked whether 
the Rule poses an impediment to this 
goal. The Rule currently requires either 
a washing instruction or a dry cleaning 
instruction; it does not require both. 
Thus, garments that can legally be 
labeled with a “dry clean” instruction 
alone also may in some cases be 
washable, a fact not ascertainable from 
such an instruction. The 1994 FRN 
asked about the extent of care labeling 
that fails to indicate both washing and 
dry cleaning instructions. Finally, the 
1994 FRN asked whether the use of dry 
cleaning solvents would be lessened, 
and whether consumers and cleaners 
could make more informed choices as to 
cleaning method, if the Rule were 
amended to require both washing and 
dry cleaning instructions for garments 
cleanable by both methods. 59 FR 
30733-34. 

In the 1995 ANPR, the Commission 
analyzed the comments submitted in 
response to the 1994 FRN and proposed 
amending the Rule to ensure that 
consumers are provided with 
information that would allow them the 
choice of washing garments when 
possible. The Commission concluded 
that lack of such information can result 
in substantial injury to consumers in the 
form of unnecessary expense and/or the 
inability to use what they regard as a 
more environmentally friendly method 
of care. 60 FR 67104-05. 


clearinghouse for information on emissions control; 
one home appliance manufacturers trade 
association; one manufacturer of home appliances; 
one home applicance repairman; one international 
association for textile care labeling: one federal 
agency; and the Economic Union of European 
Countries. The comments are on the public record 
and are available for public inspection in 
accordance with the Freedom of Information Act. 5 
U.S.C. 552, and the Commission’s Rules of Practice. 
16 CFR 4.11, at the Public Reference Room. Room 
130, Federal Trade Commission, 6th and 
Pennsylvania Avenue, Washington. D.C. The 
comments are referred to in this Notice of Proposed 
Rulemaking (‘‘NPR’’) by their name and the number 
assigned to each submitted comment. 

2 Congress designated PCE as a hazardous air 
pollutant in Section 112 of the Clean Air Act; many 
state legislatures have followed suit under state air 
toxics regulations. 


The ANPR asked for comment on an 
amendment of the Rule to require a 
home washing instruction for all 
covered products for which home 
washing is appropriate; providing dry 
cleaning instructions for such washable 
items would be optional. Manufacturers 
marketing items with a “Dry Clean” 
instruction alone would be required to 
substantiate both that the items could be 
safely dry cleaned and that home 
washing would be inappropriate for 
them (as the Rule currently requires 
them to do when providing a “Dry 
Clean Only” instruction). This proposal 
would not result in the additional 
substantiation testing (and increased 
PCE use) that the comments suggested a 
“dual disclosure” requirement could 
necessitate, because a dry cleaning 
instruction would be optional, as would 
the necessary substantiation to support 
it. Id. at 67105. That is, manufacturers 
labeling their goods for home washing 
(and possessing the appropriate 
substantiation for that instruction) 
would not have to also provide a dry 
clean instruction or have substantiation 
that dry cleaning would harm the 
garment. 

Fifty-three comments addressed 
whether the Commission should require 
a home washing instruction for items 
that could be safely washed at home, 
and only three of those opposed the 
proposal. 3 

Eighteen commenters, including 
individual consumers, academics, and 
an appliance manufacturers’ trade 
association, contended that many 
manufacturers currently label items that 
can be both washed and dry cleaned 
with a “dry clean” or “dry clean only” 
instruction.” 4 Many commenters 
stressed that knowing that garments can 
be washed at home would save them (or 
consumers in general) garment care 
dollars. 5 Two consumers stated that 


3 Aqua Clean Systems. Inc. ("Aqua Clean”) (34) 
pp. 8-9; Center for Emissions Control (“CEC") (44) 
pp. 5-6; American Apparel Manufacturers 
Association ("AAMA”) (57) p.2. 

* Henry Gluckstem, Esq. (16) pp. 1-2; Bette Jo 
Dedic, University of Kentucky College of 
Agriculture Extension Service ("Univ. of KY”) (20) 
p. 1; Vera Rines (28) p. 1; Thelma Carpenter (30) 
p. 1; Katherine King (32) p. 1; Ida Carpenter (33) 
p. 1; Margie Helton (38) pp. 1-2; Jewell Brabson 
(40) p. 1; Susan DuBois (42) p. 1; UCLA Pollution 
Prevention Education and Research Center (“UCLA 
PPERC") (45) p. 3; Aileen Mills (47) p. 1; 
Association of Home Appliance Manufacturers 
("AHAM”) (51) p. 2.; Helen DuBois (52) p. 1; M. 
Adkins (54) p. 1: Teresa Mills (58) p. 1; Sarah 
O’Neal (59) p. 1; Frances McCarter (61) p. 1; Gladys 
Bebber (62) p. 1. But see Aqua Clean (34) p. 8: “As 
a general observation, garments which can be home 
laundered or drydeaned are usually labeled with 
both care instructions.” 

3 Univ. of KY (20) p. 1; Vera Rines (28) p. 1: 
Thelma Carpenter (30) p. 1; Katherine King (32) p. 

1; Ida Carpenter (33) p. 1; Carolyn Powers (35) p. 


washing garments that are labeled “dry 
clean” or “dry clean only” but that 
appear washable (such as 100% cotton) 
is risky because, if the garment is 
ruined, the manufacturer will not stand 
behind it. 6 AHAM, a trade association 
for appliance manufacturers, noted that: 
the cost for testing a garment fabric sample 
for proper care instructions is just a fraction 
of the consumer expense experienced by 
many thousands of individuals incurring 
ongoing dry cleaning expenses for a garment 
that could be washed at home. 7 

Many commenters also noted that 
consumers believe there are 
environmental benefits from home 
washing rather than dry cleaning 
washable items. 8 Consumers Union 
stated, “If only one method must appear 
on the label, it has to be the least 
expensive and the least hazardous to the 
consumer and the environment.” 9 

Three commenters recommended that 
both washing and dry cleaning 
instructions be included if both are 
appropriate. 10 Two comments 
specifically opposed this type of “dual 
labeling,” however, because of the 
increased levels of dry cleaning 
substantiation tests that would follow. 11 

Two commenters (one of which is an 
association for apparel manufacturers) 
argued that manufacturers (having made 
the items) are best qualified to make the 
decision as to how garments can best be 
cleaned and urged the Commission to 
leave apparel manufacturers the 


1; Spencer and Diana Hart (36) p. 1; Margie Helton 

(38) pp. 1-2; Jewell Brabson (40) p. 1; Susan DuBois 

(42) p. 1; Aileen Mills (47) p. 1; Joyce Rash (48) p. 

1; S.K. Taylor (49) p. 1; Helen DuBois (52) p. 1; M. 
Adkins (54) p. 1; Teresa Mills (58) p. 1; Sarah 

O’Neal (59) p. 1: Frances McCarter (61) p. 1; Gladys 
Bebber (62) p. 1. 

•Dana Dodson (4) p. 1; Margaret Petty (37) p. 1. 

7 AHAM (51) p. 2. 

•Linda Smith, Tenn. State Univ. Cooperative 
Extension Program (3) p. 1; John ft Elizabeth Gray 
(15) p. 1; Univ. of KY (20) p. 2; Vera Rines (28) p. 

1; Thelma Carpenter (30) p. 1; Katherine King (32) 
p. 1; Ida Carpenter (33) p. 1; Margie Helton (38) pp. 
1-2; Jewell Brabson (40) p. 1; Susan DuBois (42) p. 

1; Consumers Union (46) p. 2; Aileen Mills (47) p. 

1; S.K. Taylor (49Fp. 1; Helen DuBois (52) p. 1; M. 
Adkins (54) p. 1; Teresa Mills (58) p. 1; Sarah 
O’Neal (59) p. 1; Frances McCarter (61) p. 1; Gladys 
Bebber (62) p. 1. 

•Consumers Union (46) p. 2. 

10 International Fabricare Institute ("in”) (56) p. 

2; Ginetex (the International Association for Textile 
Care Labeling) (63) p. 4; European Union (64) p. 3. 

11 Univ. of KY (20) p. 2; Consumers Union (46) 
p. 2. See also the discussion of “dual disclosures” 
in the ANPR; 

The Commission has learned from several 
commenters. primarily manufacturers, that 
requiring both washing and dry clean labels (a 
"dual disclosure" amendment) would require a dry 
cleaning instruction on virtually all washable items. 
According to these commenters, this would 
necessitate additional testing expenses for 
manufacturers and a resulting increase in PCE use. 
to the detriment of human health and the 
environment. (60 FR 67105. n. 30). 









Federal Register/ Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


25419 


flexibility to decide which care 
instructions to use . 12 A third commenter 
in opposition to the proposal, a non¬ 
profit clearinghouse for information on 
emission control in chlorinated solvent 
applications, including dry cleaning, 
stated that there did not appear to be 
many instances of washable items being 
labeled “dry clean .” 13 

b. Proposed Amendments and Reasons 
Therefor 

Based on the comments, the 
Commission has reason to believe that 
“dry clean” labels on home-washable 
items are prevalent and that consumers 
have a preference for being told when 
items that they are purchasing can be 
safely washed at home. Moreover, the 
information about washability may be 
important to consumers for economic or 
environmental reasons, or both. Some 
consumers wish to avoid the use of PCE 
and clean in water when possible 
because they believe it is better for the 
environment. The record also supports 
the conclusion that this aspect of the 
Rule is an impediment to EPA’s goal of 
reducing the use of dry cleaning 
solvents . 14 

When a garment that can be washed 
at home is labeled “dry clean,” many 
consumers may be misled into believing 
that the garment cannot be washed at 
home, and they may incur the 
unnecessary expense of dry cle aning the 
garment and/or potential damage to the 
environment that they wish to avoid . 15 
Moreover, it can be extremely difficult 
for consumers to obtain the information 
about washability of an item for 
themselves. Although fiber content can 
be a guide to washability, other 
factors—such as the type of dye or 
finish used—can also determine 
washability, and consumers have no 
way of learning what dyes and finishes 


12 Aqua Clean (34) pp. 8-9; AAMA (57) p. 2, 
noting that ‘There are some garments with ‘dry 
clean only’ labels that can be washed at home 

* * * * but if the cleaning is not done correctly, it 
can lead to damage. 

"CEC (44) p. 5. 

14 EPA’s comment (73) to the 1994 FRN stated, at 
p. 1, that the Rule should be revised to require 
manufacturers to state whether a garment "can be 
cleaned by solvent-based methods, water-based 
methods, or both. We believe this change is 
necessary to advance the use of water-based 
cleaning technology.” EPA’s comment to the 1995 
FRN referred to the 1994 comment, and stressed the 
need for recognition in the Rule of professional wet 
cleaning. EPA (17) p. 1. 

15 A Perdue University survey found that 89.3% 
of the 962 respondents indicated that they would 
not wash a garment labeled ‘‘dry clean.” Staff 
Report to the Federal Trade Commission and 
Proposed Revised Trade Regulation Rule (16 CFR 
Part 423) (May 1978), p. 141. Other surveys showed 
similar results. Id. at 142-143. 


were used and whether they will 
survive washing. 

Accordingly, the Commission 
proposes amending the Rule to require 
a home washing instruction for 
garments for which home washing is 
appropriate. This amendment would 
permit optional dry cleaning 
instructions for such washable items, 
provided dry cleaning would be an 
appropriate alternative cleaning 
method. The amendment would, 
however, require that manufacturers 
selling items with a “dry clean” 
instruction alone be able to substantiate 
both that the items could be safely dry 
cleaned and that home washing would 
be inappropriate for them. 1 ® 

As noted in the comments, the 
proposed amendment would enable 
consumers to make a more informed 
purchasing choice and provide them 
with the option of saving money by 
washing at home instead of incurring 
the higher expenses of dry cleaning. In 
addition, consumers who are concerned 
about reducing the use of PCE will have 
information about the “washability” of 
all apparel items they are considering 
purchasing. 

The Commission agrees, as it did in 
the ANPR, with the commenters 
(primarily manufacturers) that 
cautioned against a “dual labeling” 
instruction requiring both home 
washing and dry cleaning instructions if 
both methods are appropriate. Such an 
instruction would result in some 
manufacturers of traditionally washable 
products performing dry cleaning tests 
to substantiate that dry cleaning was an 
appropriate care method, which would 
be contrary to EPA’s goal of reducing 
the use of dry cleaning solvents. 
Moreover, the comments do not indicate 
a consumer preference for such dual 
labeling. The Commission has no reason 
to believe at this time that it is either 
unfair or deceptive for a manufacturer 
or importer to fail to reveal that a 
garment labeled for washing can also be 
dry cleaned, and to require such dual 
labeling might raise costs without 
providing any real benefit to consumers. 

The proposed amendments would 
permit a home washing instruction only 
for those covered products for which 
home washing—and traditional home 
finishing processes such as ironing— 
would be an appropriate method of care. 
Many commenters cautioned that, for 


'•The Rule currently requires this level of 
substantiation for a “dry clean only” instruction. 
Under the proposed amendment, any garment for 
which home washing is not recommended and dry 
cleaning is recommended, would have to be labeled 
“dry clean only.” In other words, a "dry clean” 
instruction by itself would no longer be 
permissible. 


some items that could be washed in 
water, there would be many additional 
finishin g steps required for the garment 
that the average consumer could not 
perform at home. In the case of some 
garments, such as suits made from wool 
or silk (fibers that generally can be 
safely washed in water), post-home 
washing finishing processes like 
steampressing and pleat and crease 
setting are necessary for proper 
refurbishing. These processes are 
beyond the capabilities of most 
consumers and the equipment available 
to them . 17 Under the proposed 
amendments, a home washing 
instruction would not be appropriate or 
required for an item that could be safely 
washed in water with the proper 
cleaning agents but could not be 
finished properly at home by the 
average consumer. Moreover, the 
Commission recognizes that 
manufacturers have experience with the 
consumers who buy their garments, and 
the Commission would expect to defer 
to manufacturers’ decisions in the case 
of garments that would be difficult to 
refurbish for some but not all 
consumers . 18 

2. The “Professionally Wet Clean” 
Instruction 

a. Background and Discussion of 
Comments 

The ANPR asked whether the Rule 
should he amended to recognize the 
new technology referred to as 
“professional wet cleaning” by 
requiring a professional wet cleaning 
instruction for products that cannot be 
washed at home but could be cleaned by 
means of this new technology . 19 
(Professional wet cleaning uses 
computer-controlled washers and dryers 
to achieve precise control of mechanical 
action, fluid levels, temperatures, and 
other important factors.) The ANPR 
asked for information on the cost of wet 
cleaning, the availability of wet cleaning 
facilities, whether the process currently 
could serve as a practical alternative to 
dry cleaning, and whether fiber 


17 See Aqua Clean (34) pp. 6-9. 

'•In addition, manufacturers that wished to stress 
that a particular garment could be refurbished at 
home but might be difficult for some consumers to 
refurbish adequately at home could add a phrase 
such as ‘Tor best results, dry clean.” 

'•In the narrative discussing this issue in the 
ANPR, the Commission sought information on the 
feasibility of a "professionally wet clean” 
instruction on “all covered products bearing a dry 
cleaning instruction.” 60 FR 67105. In the Request 
for Comments Section of the Notice, however, the 
Commission limited the applicability of the 
question to “a garment that cannot be home 
laundered but can be dry cleaned.” 60 FR 67107. 
Most of the commenters responded in the latter 
context 













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Federal Register/Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


identification should be on a permanent 
label. 60 FR 67105, 67107. 

Twenty-nine commenters addressed 
the “professionally wet clean” 
instruction. 20 Only four opposed the 
proposal to amend the Rule to require 
a “professionally wet clean” instruction 
for wet cleanable garments that qannot 
be washed at home. The Soap and 
Detergent Association and Procter & 
Gamble contended that the term 
“professionally wet clean” may be 
confused with a home washing 
instruction by consumers. 21 The Center 
for Emissions Control contended that 
wet cleaning is a new technology that is 
neither well understood nor widely 
available, and that a required wet 
cleaning instruction now would 
therefore be unreasonable and 
counterproductive. 22 SDA, P&G, and 
CEC all recommended requiring some 
version of a “professionally clean” 
instruction that would encompass both 
dry cleaning and professionally wet 
cleaning. 23 CEC also suggested that 
eventually the Rule could provide for a 
“professionally wet clean" instruction 
that would be permitted, but not 
required, when the manufacturer 
thought professional wet cleaning 
would be appropriate. 24 AAMA opposed 
any provision in the Rule for 
professional wet cleaning on the ground 
that it is too new and that there are too 
few cleaners who can provide the 
service. 23 

(1) Defining Professional Wet 
Cleaning. 26 Six organizations provided 


20 Joyce McCarter (14) p.l; John 4 Elizabeth Gray 
(15) p.l; Henry Gluckstem, Esq. (16) pp.l, 3; EPA 
(17) p.l; Linda Arant (18) p.l: Vera Rines (28) p.l; 
Thelma Carpenter (30) p.l: Ida Carpenter (33) p.l; 
Aqua Clean (34) pp. 6-7; Margie Helton (38) p.l; 
)ewell Brabson (40) p.l; American Textile 
Manufacturers Institute (“ATMI”) (41) p.3: Susan 
DuBois (42) p.l: The Soap and Detergent 
Association (“SDA”) (43) pp.l; 3; CEC (44) pp.l- 
2. 5; UCLA PPERC (45) pp.2-3: Consumers Union 
(46) pp.1-2; Center for Neighborhood Technology 
(“CNT") (55) pp.2, 4; FI (56) p.2.; AAMA (57) p.2; 
Teresa Mills (58) p.l; Sarah O’Neal (59) p.l; P4G 
(60) pp.2; 4; Frances McCarter (61) p.l: Gladys 
Bebber (62) p.l; Ginetex (63) p.3. 

SDA (43 pp.l. 3; Procter 4 Gamble (“P4G”) (60) 
pp.2. 4. 

21 CEC (44) p.5. 

23 SDA (43) pp.l. 3; CEC (44) pp.1-1. 5; P4G (60) 
pp.2. 4. 

24 CEC (4) p.5. 

23 AAMA (57) p.2. 

*»The ANPR noted that EPA had published a 
summary of an alternative cleaning process referred 
to as “Multiprocess Wet Cleaning.” 60 FR 67103 
(Dec. 28.1995). According to several commenters, 
"multiprocess wet cleaning” is a cleaning process 
that involves knowledgeable individuals hand¬ 
cleaning individual garments, often employing a 
“spot cleaning" technique rather than full 
immersion, and using water, heat, steam and 
natural soaps instead of perchloroethylene or 
petroleum solvents. Aqua Clean (34) pp.1-2. noting 
that "Professional wet cleaning has already 
supplanted multiprocess wet cleaning. Indeed, 


information describing the wet cleaning 
process. 27 They defined “machine wet 
cleaning” or “professional wet 
cleaning” as an automatic, water-based 
cleaning process that relies on the use 
of sophisticated, computer-controlled 
washers and dryers in which the 
washing and drying cycles, including 
heat, moisture, and agitation, can be 
precisely controlled according to 4 the 
requirements of the various fiber, fabric, 
and garment types. 28 

Three organizations provided 
information about the equipment used 
in professional wet cleaning. 29 UCLA 
PPERC and CNT said that five 
companies provide the equipment 
systems necessary for professional wet 
cleaning. 30 Aqua Clean provided a 
detailed description of the equipment 
needed to provide professional wet 
cleaning services: 

All professional wet cleaning systems consist 
of a computer-controlled washer and dryer, 
wet cleaning software, and biodegradable 
chemicals specifically formulated to safely 
wet clean wool, silk, rayon, and other natural 
and man-made fibers. The washer always 
uses a frequency-controlled motor, which 
allows the computer to precisely control the 
degree of mechanical action imposed on the 
garments by the wet cleaning process. The 
computer also controls time, fluid levels, 
temperatures, extraction, chemical injection, 
drum rotation and extraction parameters, etc. 
The dryer always incorporates a residual 
moisture (or humidity) control to prevent 
overdrying of delicate garments. The wet 
cleaning ciemicals are formulated from 
constituent chemicals which are on the 
EPA’s public inventory of approved 
chemicals pursuant to the Toxic Substances 
Control Act (TSCA). 31 

(2) As an Alternative to Dry Cleaning. 
The ANPR asked two related questions 
about the feasibility of wet cleaning as 
a practical alternative to dry cleaning, 
and the extent to which items that have 
historically been dry cleaned could 
successfully be professionally wet 
cleaned. Five commenters responded 
directly to the first question. ATMI and 
AAMA pointed out that, while the fibers 
and dyes now in use will stand up to 
the chemical solvents used in the dry 
cleaning process, the textile industry 
does not know if they will stand up to 


those cleaners (Ecofranchising, NY; Cleaner Image, 
CT) which initially used multiprocess wet cleaning 
have converted to professional wet cleaning 
because of the economic advantages.” See also CEC 
(44) p.4. Consequently, Multiprocess Wet Cleaning 
is not addressed in the remainder of this Notice. 

27 Aqua Clean (34) pp.1-2; CEC (44) p.4; UCLA 
PPERC (45) p.3; CNT (55) p.2; FI (56) p.2; Ginetex 
(63) p.3. 

28 Aqua Clean (34) pp.1-2; UCLA PPERC (45) p.3. 
28 Aqua Clean (34) pp.2-3; UCLA PPERC (45) p.3; 

CNT (55) p.2. 

20 UCLA PPERC (45) p.3; CNT (55) p.2. 

31 Aqua Clean (34) pp.2-3. 


professional wet cleaning. 32 ATMI 
predicted that: 

If consumers just assume that they can use 
the new cleaning method on their existing 
wardrobe and current clothing purchases, we 
would expect to see an increase in apparel 
damage claims. This is because the fabrics 
used in these clothing items have finishes 
and formulations designed for dry cleaning. 
We told EPA that the industry would need 
a long phase-in time (2—3 years) to adjust 
our dyes and finishes to work compatibly 
with “wet clean” processes. 33 

Ginetex, whicn is responsible for the 
care labeling system used in European 
countries, indicated its interest in the 
wet cleaning technique, but said it is 
waiting for a standardized test method 
so manufacturers can test garments to 
determine whether wet cleaning would 
be a safe care method. 34 EFI cautioned 
that wet cleaning technology is new and 
stated its determination to undertake 
research into the process: 

The use of machine wet cleaning is still in 
the investigative or infant stage. The 
technology originated in Europe and the most 
extensive analysis of these systems has been 
completed by two European research 
groups—Hohenstein and FCRA. The 
conclusion of these studies is that machine 
wet cleaning is an adjunct to dry cleaning, 
not a complete replacement The 
Environmental Protection Agency, as a result 
of its evaluation of wet cleaning under its 
Design for the Environment Program, 
concludes that machine wet cleaning is not 
a complete replacement for drycleaning. 
There is still much investigative work to be 
done In this area. To that end, IFI has formed 
a partnership with Greenpeace, other 
industry groups, and other environmental 
and labor groups to explore the possibilities 
of wet cleaning—The Professional Wet 
Cleaning Partnership. 35 

Aqua Clean estimated that 90% of 
garments can be safely and satisfactorily 
cleaned by professional wet cleaning. 
Aqua Clean stated that it has found no 
significant wetcleanability versus 
diycleanability differences applicable to 
wool, silk, rayon, acetate, linen, etc. 
with the exception of heavier wool 
suits, which are made with linings and 
shoulder pads that dry at a rate different 
from the wool, and thus require extra 
time. 36 CEC stated that estimates of the 
percentage of garments labeled “dry 
clean only” that can be successfully wet 

32 ATMI (41) p.3; AAMA (57) p.2. 

33 ATMI (41) p.3. 

34 Ginetex (63) p.3. 

33 FI (56) p.2. 

30 Aqua Clean (34) p.4. Aqua Clean said that it has 
corresponded with the International Wool 
Secretariat (IWS). the research and marketing arm 
of the wool industry, and anticipates cooperating 
with the IWS's announced intention to develop 
wool processing technologies at the mill level that 
will make wool garments better suited to 
professional wet cleaning, so they can be dried 
faster at higher temperatures. Id. at 5. 







Federal Register /Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


25421 


cleaned vary from 30% to 70%, with 
industry experts narrowing that spread 
to 30°/° t0 50%. 37 IFI contended that it 
is too early to estimate the percentage 
vvitb any certainty, but stated that early 
indications are that the percentage of 
“dry clean” labeled garments that could 
be effectively machine wet cleaned 
could be anywhere from 25% to 75%. 38 
CNT estimated, based on its own 
research and research conducted by 
Environment Canada, that from 30% to 
70% of clothes generally cleaned in PCE 
could be safely cleaned using standard 
commercial or domestic laundering 
equipment. 39 

(3) Businesses that Provide Wet 
Cleaning. When it filed its comment in 
early 1996, Aqua Clean estimated that, 
by the end of 1996, approximately 350 
businesses would have professional wet 
cleaning systems. 40 Three other 
commenters estimated that professional 
wet cleaning is currently being offered 
by 100 businesses. 41 CEC also estimated 
that it will be several years, even at best, 
before a substantial number of the 
nation’s 30,000 cleaners have purchased 
professional wet cleaning technology. 42 

(4) Costs to Consumers. ATMI said 
that the additional costs incurred by 
textile and apparel manufacturers to 
substantiate a wet cleaning instruction 
would be passed on to consumers. 43 
Both UCLA PPERC and CNT stated that 
the costs to consumers for wet cleaning 
services are comparable to the costs of 
dry cleaning. 44 CNT estimated that the 
range for wet cleaning a two-piece wool 
suit was from $4.50 to $9.00, and added 
that interviews with cleaners indicated 
that those who provided both types of 
cleaning were providing them for 
approximately the same cost, and that in 
no case were charges for wet cleaning 
higher than for dry cleaning. 45 

Aqua Clean said that it was not aware 
of any cleaner charging more for wet 
cleaning services than for dry cleaning 
services, and that in some cases the cost 
of wet cleaning is less, because many 
dry cleaners impose a surcharge 
(typically 50 cents) to cover the rising 
cost of disposing of hazardous dry 
cleaning waste. 46 


37 CEC (44) p.4. 

38 ER (56) p.2. 

38 CNT (55) p.2. 

40 Aqua Clean (34) p.3. 

41 UCLA PPERC (45) p.3; CNT (55) p.3; AAMA 
(57) p.2. 

42 CEC (44) p.5. 

43 ATMI (41) p.3. 

44 UCLA PPERC (45) p.4; CNT (55) p.4. 

45 CNT (55) p.4. 

48 Aqua Clean (34) p.5. Aqua Clean also raised an 
issue that was nqt addressed in the ANPR— 
consumer access to cleaning services: 

Many developers and owners of strip centers and 
shopping centers, which is where most consumers 


(5) The Environmental Impact of the 
Process. Aqua Clean and CNT stated 
that none of the substances used in the 
process are prohibited by EPA; further. 
Aqua Clean said that the only materials 
released into the environment in 
connection with the process are 
chemicals that appear on EPA’s public 
inventory of approved chemicals under 
the Toxic Substances Control Act. 47 CEC 
suggested, however, that the primary 
environmental issue associated with the 
wet cleaning process is water 
consumption, because the process uses 
2.5 gallons of water to clean a pound of 
clothes. CEC pointed out that, although 
this compares favorably to the 6 gallons 
per pound used by home clothes 
washers, the wet cleaning process uses 
more water than the dry cleaning 
process, which uses water primarily for 
cooling purposes, and typically recycles 
it. 4 ® UCLA PPERC stated that research 
suggests that wet cleaning is a safe 
alternative to dry cleaning. 49 

The Commission notes that it has not 
made an independent assessment of the 
environmental desirability of the 
various methods of cleaning textile 
wearing apparel. Rather, it has noted 
EPA’s goal of reducing the use of dry 
cleaning solvents and the preference of 
numerous consumers for information 
about whether garments can be cleaned 
in water. The Commission has prepared 
a proposed Environmental Assessment 
in which it analyzed whether the 
amendments to the Rule were required 
to be accompanied by an Environmental 
Impact Statement. Because the main 
effect of the proposed amendments is to 
provide consumers with additional 
information rather than directly to affect 
the environment, the Commission 
concluded in the proposed 
Environmental Assessment that an 
Environmental Impact Statement is not 
necessary. The Commission requests 
comment on this issue. The 
Environmental Assessment is on the 


access cleaning services, are refusing to rent space 
to or renew leases for drycleaners. These landlords 
simply do not want to bear the legal exposure or 
insurance expense associated with drycleaning 
machines and their toxic waste stream. Aqua Clean 
Systems is currently negotiating with a major 
national shopping center owner to become their 
exclusive tenant for 100% perc-free cleaning 
facilities. At present, they refuse to allow a 
drycleaner in any of their 1,800 shopping centers. 
Similar discussions are taking place with a major 
chain in the Southeast. This trend will continue. If 
the Rule is not amended to accommodate 
professional wet cleaning, access to cleaning 
services will decline as regulatory and landlord 
pressures cause a decline in the number of 
drycleaners, which will eventually reduce 
competition and cause an increase in consumer 
prices. Id., pp. 9-10. 

47 Aqua Clean (34) p.3: CNT (55) p.3. 

48 CEC (44) p.3. 

48 UCLA PPERC (45) p.4. 


public record and is available for public 
inspection at the Public Reference 
Room, Room 130, Federal Trade 
Commission, 6th and Pennsylvania 
Avenue, Washington, D.C. It can also be 
obtained at the FTC’s web site at http:/ 
/www.ftc.gov on the Internet. 

(6) The Requirement for Fiber 
Identification on a Permanent Label. 
Eight comments addressed the 
desirability of a requirement for fiber 
identification on a permanent label, and 
all favored the idea. 50 Five 
recommended that the fiber 
identification be on the same label as 
the care instructions. 51 Several 
commenters said that fiber information 
need not necessarily be on the care label 
but should be on a permanent label. 52 
Most of the commenters said that 
cleaners need fiber identification 
information in order to provide the best 
cleaning services for their customers. 
Aqua Clean explained as follows: 

(F)abric identification (should) be on a 
permanent label because it is essential 
information for all cleaners regardless of the 
technology employed; requiring this by 
regulation will merely codify a nearly 
uniform practice at no measurable cost to 
manufacturers. A secondary consideration is 
that individuals with allergies to certain 
fibers (e.g., wool) should be provided with 
this information. It is clear that requiring 
fiber identification on a permanent label 
should be acceptable to manufacturers and 
consumers because it has already become an 
accepted part of business at all levels of 
manufacture, distribution, sales, and garment 
care. 53 

b. Proposed Amendment and Reasons 
Therefor. The comments show that 
professional wet cleaning is a process 
that is of interest to consumers, 
especially those who believe it has the 
potential for less negative impact on the 
environment than dry cleaning. Thus, 
the Commission is proposing 
amendments that will incorporate 
professional wet cleaning into the Rule’s 
system of instructions for care. 

Nevertheless, professional wet 
cleaning is a very new technology, and 
it does not appear to be widely 
available. Moreover, there is not a 
standardized test by which 
manufacturers can establish a 
reasonable basis for a professional wet 

S0 Univ. of KY (20) p. 1; Aqua Clean (34) p. 7; 
ATMI (41) p. 4; CEC (44) p. 2; UCLA PPERC (45) 
p. 3; Consumers Union (46) p. 2; AHAM (51) p. 2; 
P&G (60) p. 4. 

81 CEC (44) p. 2; UCLA PPERC 945) p. 3; 
Consumers Union (46) p. 2; AHAM (51) p. 2; P4G 
(60) p. 4. 

52 Univ. of KY (20) p. 1; Aqua Clean (34) p. 7. 

83 Aqua Clean (34) p. 7. 







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Federal Register/ Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


cleaning instruction. 54 For these 
reasons, the Commission is not at this 
time proposing an amendment to the 
Rule that would require a wet cleaning 
instruction. Instead, the Commission is 
proposing amendments that would add 
a definition to the Rule for “professional 
wet cleaning” and would permit 
manufacturers to include a 
“professionally wet clean” instruction 
on labels for those items for which they 
have a reasonable basis for a 
professional wet cleaning instruction. 
The proposed amendments do not 
require manufacturers who label items 
with a “dry clean only” instruction to 
be able to substantiate that professional 
wet cleaning would be an inappropriate 
method of care. 

The Commission also concludes that 
fiber identification on a permanent label 
is important to professional wet 
cleaners. 55 The record contains 
numerous references to the need for 
precise fiber content information due to 
the complexity of the computer- 
controlled equipment used in the wet 
cleaning process. Therefore, the 
proposed amendment requires that, if a 
care instruction recommends 
professional wet cleaning, the fiber 
content must be provided on the 
permanent care label along with the care 
instructions. The Commission seeks 
comment as to whether any 
accompanying change should be made 
to the Textile Rules. 56 

Finally, it should be noted that at this 
time, the Commission proposes 
allowing a “professional wet clean” 
instruction along with a conventional 
care instruction because many 
consumers do not currently have access 
to professional wet cleaners. 
Nevertheless, because professional wet 
cleaning appears to be growing rapidly, 
the Commission seeks comment on this 
point. 


34 Testing is one of several types of evidence that 
can serve as a reasonable basis for a care 
instruction. 

55 The Textile Fiber Products Identification Act 
("Textile Act"). 15 U.S.C 70 el seq., requires 
marketers of covered textile products to mark each 
product with the generic names and percentages by 
weight of the constituent fibers present in the 
product. The Commission has issued Rules and 
Regulations under the Textile Act ("Textile Rules”). 
Rule 15 of the Textile Rules, 15 CFR 303.15, allows 
any type of label to be used as long as the label is 
securely affixed and durable enough to remain 
attached to the product until the consumer receives 
it; Rule 15 does not require a permanent label. 

56 Rule 16 of the Textile Rules, 16 CFR 303.16, 
requires, with some exceptions, that all information 
required by the Textile Act shall be set out on one 
label, and on the same side of the label. The 
Commission recently sought comment on 
modifications of the Textile Rules. 61 FR 5344 (Feb. 
12, 1996). 


3. The Reasonable Basis Requirement of 
the Rule 

a. Background and Discussion of 
Comments 

The Rule requires that manufacturers 
and importers of textile wearing apparel 
possess, prior to sale, a reasonable basis 
for the care instructions they provide. 
Under the Rule, a reasonable basis must 
consist of reliable evidence supporting 
the instructions on the label. 16 CFR 
423.6(c). Specifically, a reasonable basis 
can consist of (1) reliable evidence that 
the product was not harmed when 
cleaned reasonably often according to 
the instructions; (2) reliable evidence 
that the product or a fair sample of the 
product was harmed when cleaned by 
methods warned against on the label; (3) 
reliable evidence, like that described in 
(1) or (2), for each component part; (4) 
reliable evidence that the product or a 
fair sample of the product was 
successfully tested; (5) reliable evidence 
of current technical literature, past 
experience, or the industry expertise 
supporting the care information on the 
label; or (6) other reliable evidence. Id. 

The 1994 FRN solicited comment on. 
whether the Commission should amend 
the Rule to conform with the 
interpretation of “reasonable basis” 
described in the FTC Policy Statement 
Regarding Advertising Substantiation, 
(“Advertising Policy Statement”) 104 
F.T.C. 839 (1984), or to change the 
definition of “reasonable basis” in some 
other manner. The comments in 
response to the 1994 FRN suggested that 
a significant number of care labels lack 
a reasonable basis. Based on these 
comments, the ANPR proposed 
amending the reasonable basis 
requirement to reduce the incidence of 
inaccurate and incomplete labels. The 
ANPR sought comment on that 
incidence, the extent to which it might 
be reduced by clarifying the reasonable 
basis standard, and the costs and 
benefits of such a clarification. 

The Commission further solicited 
comment on whether to amend the Rule 
to clarify that the reasonable basis 
requirement applies to a garment in its 
entirety rather than to each of its 
individual components. In addition, the 
Commission asked for comment on 
whether the Rule should specify 
standards for determining acceptable 
and unacceptable changes in garments 
following cleaning as directed, and 
whether the Rule should identify 
properties, such as colorfastness and 
dimensional stability, to which such 
standards would apply. 

The ANPR sought comment on the 
option of indicating in the Rule that 
whether one or more of the types of 


evidence described in Section 423.6(c) 
constitutes a reasonable basis for care 
labeling instructions depends on the 
factors set forth in the Advertising 
Policy Statement and whether the Rule 
should be amended to make testing of 
garments the only evidence that could 
serve as a reasonable basis under certain 
circumstances. Finally, the ANPR 
sought comment on whether the Rule 
should specify particular testing 
methodologies to be used. Ten 
commenters responding to the ANPR 
discussed the reasonable basis 
provision. 57 Seven supported the 
modification of the Rule, arguing that 
the provision should be clarified and 
strengthened to reduce mislabeling. 58 
Two maintained that the reasonable 
basis provision should not be amended, 
because the proposed changes would 
likely increase the cost to consumers 
and apparel firms without materially 
increasing the benefits to consumers. 59 

Only two commenters provided data 
on the incidence of mislabeling. Both 
concluded that there is a high incidence 
of inaccurate and/or incomplete 
labeling. IFI cited statistics from its 
Garment Analysis database (which, in 
1995, consisted of 25,160 damaged 
garments) indicating that inaccurate 
care labels were responsible for 40% of 
the damaged garments. 60 Clorox 
concluded from its own study that 70% 
of all home washing instructions 
provide inaccurate bleach 
information. 81 

ATMI, however, stated that most 
home washing labels are accurate, and 
that the vast majority of dry clean 
instruction labels are accurate, despite 
limited problems associated with care 
instructions for special items such as 
beaded apparel, sequins, and leather 
appliques. 6 ? ATMI and AAMA both 


57 Univ. of KY (20) p.2; Clorox (31) pp. 4-5; ATMI 
(41) pp. 5-7; SDA (43) pp. 1,3; Consumers Union 
(46) pp. 2-3; AHAM (51) p.2; IFI (56) p. 3; AAMA 
(57) p. 2; P&G (60) p. 5; Ginetex (63) p.4. 

38 Univ. of KY (20) p. 2; Clorox (31) pp. 4-5; SDA 
(43) pp. 1,3; Consumers Union (46) pp. 2-3; AHAM 
(51) p. 2; IFI (56) p. 3: P&G (60) p. 5. 

39 AAMA (57) p. 2; ATMI (41) pp. 5-7. Ginetex, 
the European care labeling organization, stated that 
it gives technical advice "to give indications how 
to test in the case of uncertainty to choose the 
con-ect care label." Ginetex (63) p. 4. 

90 IFI (56) p.3. 

81 Clorox (31) p.2. 

62 ATMI (41) p.5. See also AAMa (57) p.3 ("There 
are a few problems with leather patches and some 
other materials attached to garments.”) The 
Commission has litigated one case involving 
inaccurate care instructions that resulted in damage 
to garments. FTC v. Bonnie & Company Fashions. 
Inc. and Bonnie Boerer, Civ. Action No. 90—4454) 
(D.N.J.). In addition, since that litigation, the 
Commission has obtained five settlements that 
alleged violation of the Rule due to inaccurate care 
instructions: in three of those five settlements, the 
Commission alleged that the trim on the garments 
was damaged when cleaned. 






Federal Register /Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


25423 


stated that the costs to consumers of 
complaining to manufacturers or 
retailers about garments damaged in 
cleaning is minimal, usually consisting 
of returning that item to the store, a 
telephone call, or postage for mailing a 
letter. 63 Moreover, according to both 
commenters, garment or piece goods 
manufacturers generally offer refunds 
for products damaged in cleaning 
despite adherence to care label 
directions if numerous consumers 
complain about an item. 64 

Several commenters specifically 
addressed whether the Rule should 
require testing as a reasonable basis in 
certain situations. Two commenters 
argued that testing should be the only 
permissible reasonable basis. 65 Clorox 
stated that tests performed on a 
representative sample of each garment 
are “the most reliable evidence of care 
instruction accuracy,” and that 
textbooks and manuals should not be 
allowed as evidence of a reasonable 
basis. 66 Clorox maintained that such a 
requirement would place little 
additional expense on manufacturers 
because “published tests on specific 
fabric and dye combinations are already 
shared among the trade.” 67 

Two commenters, ATMI and AAMA, 
however, opposed such an amendment 
to the Rule. 68 ATMI expressed its 
concern that a testing requirement 
would substantially increase the prices 
for apparel and home furnishing 
items. 69 AAMA noted that its members 
already test new styles and fabrics for 
use in garments; thus, it is unaware of 
any garments which “would need a 
legal requirement to be tested.” 70 

A number of commenters discussed 
whether the rule should specify testing 
methodologies to be used. Consumers 
Union asserted that the Rule should 
specify test methods that relate to 
consumer expectations, assessing 
“product performance after repeated 
cleaning, shrinkage, colorfastness, 
appearance retention, and at least one 
fabric strength test.” 71 In contrast, 
AAMA contended that requiring 


83 ATMI (41) p.7; AAMA (57) p.4. But see Univ. 
of KY (20) p.2 (consumers may not complain to 
stores because they are intimidated or do not think 
their problems will be resolved). 

84 ATMI (41) p.7 (noting that if only one 
consumer complains about an item “of which 
thousands were produced, it is likely that the 
damage was caused by a commercial cleaner or by 
the consumer”); AAMA (57) p.4. 

• 5 IFI (56) p. 3; Clorox (31) pp. 4-5. 

68 Clorox (31) p. 4. 

87 Id. 

88 ATMI (41) p. 5: AAMA (57) p. 3. 

89 ATMI (41) p. 7. 

70 AAMA (57) p. 3. 

71 Consumers Union (46) p. 2. 


specific test methods may impede the 
introduction of new fibers and fabrics. 72 

Several commenters responded to the 
Commission’s questions relating to 
whether the Rule should require a 
reasonable basis for a whole garment 
versus each component. Three 
commenters m aintain ed that the Rule 
should require a reasonable basis for a 
garment in its entirety. 73 IFI noted that 
its database shows that “a large portion 
of the garments damaged are the result 
of the trim or component part of the 
garment failing in a specified care 
procedure.” 74 Consumers Union also 
argued that “to state an instruction that 
excludes its applicability to garment 
trim is not often practical as some trim 
are hard to remove and reposition after 
cleaning.” 75 

Two commenters stated that the Rule 
should not require testing on a complete 
garment. 76 AAMA asserted that many 
garments are made of just one major 
fabric. Accordingly, there may not be a 
need to test an entire garment, as 
opposed to the materials used, if the 
other materials used in the garment are 
of the same fiber and basic 
construction. 77 Moreover, AAMA 
argued that it is sufficient for 
manufacturers to specify in care 
instructions that a specific trim is 
excluded, because consumers are 
thereby warned that care must be taken 
when refurbishing the garment. 78 ATMI 
stated that testing of completed 
garments would significantly raise the 
cost of manufacturing apparel, but noted 
that trim should be covered by the Rule, 
and that manufacturers should be 
responsible for selecting and combining 
component materials that can be 
refurbished together. 70 

Many commenters responded to the 
Commission’s request for comments on 
whether the Rule should refer to 
performance standards, concluding that 
it may not be feasible for the Rule to do 
so. Consumers Union, for example, 
noted that because fabrics and apparel 
items are continually offered and 
discontinued, it may not be possible for 
the Commission to set performance 
standards in a timely fashion to cover 
all properties and types of garments. 80 


73 AAMA (57) p. 3. 

73 Univ. of KY (20) p. 2; Consumers Union (16) 
p. 3.; IFI (56) p. 3. 

74 IFI (56) p. 3. 

75 Consumers Union (46) p. 3. 

78 AAMA (57) p. 4: ATMI (41) pp. 5-6. 

77 AAMA (57) p. 4. 

78 Jd. 

79 ATMI (41) p. 6. 

“Consumers Union (46) p. 2 (suggesting that the 
FTC implement a rule that requires manufacturers, 
retailers, and importers to issue refunds for 
products damaged in cleaning despite adherence to 
the label). 


AAMA asserted that although there is 
“reason to look at minimum 
performance standards, including 
colorfastness, abrasion resistance, etc.,” 
the Commission should not modify the 
reasonable basis requirement until the 
United States, Mexico and Canada have 
harmonized their labeling standards. 81 

Finally, two commenters stated that 
the Commission would improve the 
effectiveness of the Rule by 
incorporating the criteria from the 
Advertising Policy Statement. 82 

b. Proposed Amendments and Reasons 
Therefor 

Section 423.6(c)(3) of the Rule 
currently states that a manufacturer or 
importer establishes a reasonable basis 
for care information by “possessing 
prior to sale: (rjeliable evidence * * * * 
for each component part of the 
product” Based on its review of the 
comments, the Commission proposes to 
amend the reasonable basis standard to 
make clear that the reasonable basis 
requirement applies to the garment in 
its entirety rather than to each of its 
individual components. The 
Commission believes that the record 
establishes that in some cases care 
instructions may not be accurate for the 
entire garment. A garment component 
that may be cleaned satisfactorily by 
itself might, for example, bleed onto the 
body of a garment of which it is a part. 
Thus, in the proposed Rule, Section 
423.6(c)(3) has been amended to clarify 
that a manufacturer must possess a 
reasonable basis for the garment as a 
whole, including any trim. 83 Proposed 
Section 423.6(c)(3) provides that 
“Reliable evidence * * * for each 
component part of the product, in 
conjunction with reliable evidence for 
the garment as a whole” can constitute 
a reasonable basis for care instructions. 
The proposed Rule does not require 
testing of the entire garment if there is 
an adequate reasonable basis for the 
garment as a whole without such 
testing; the proposed change would 
clarify, however, that testing of separate 
components is not necessarily sufficient 
if problems are likely to occur when the 
components are combined. 84 


91 AAMA (57) p. 2. 

82 SDA (43) p. 3; P&G (60) p. 5 (also suggesting 
that the Commission consider methods of 
certification and other tools such as U.S. Customs 
requirements to reduce the number of mislabeled 
imported goods, especially those labeled “Dry 
Clean Only.”) 

83 The Commission notes that an instruction to 
clean "exclusive of trim” is only a valid care 
instruction if the trim can be easily removed and 
easily reattached. 

84 For example, red trim that is to be placed on 
white fabric should be evaluated to determine if it 

Coutluued 








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Federal Register /Vol. 63, Na 89/Friday, May 8, 1998/Proposed Rules 


The Commission, however, believes 
that the comments do not provide 
sufficient reason to propose modifying 
other aspects of the reasonable basis 
provision at this time. As noted by the 
AAMA, the United States, Mexico, and 
Canada are in the process of 
harmonizing their labeling 
requirements. Until this harmonization 
is complete, the Commission believes 
that further modification of the 
reasonable basis provision may be 
premature. 

4. Definitions of Water Temperatures 

a. Background and Discussion of 
Comments 

The Rule currently requires that a care 
label that recommends washing must 
also state a water temperature that may 
be used unless “the regular use of hot 
water will not harm the product.” 16 
CFR 423.6(b)(l)(i). The Rule also 
provides that if the term “machine 
wash” is used with no temperature 
indication, “hot water up to 150 degrees 
F (66 degrees C) can regularly be used.” 
16 CFR 423.1(d). This definition is 
repeated in Appendix l.a. “Warm” is 
defined in Appendix l.b. as ranging 
from 90 to 110 degrees F (32 to 43 
degrees C), and “cold,” in Appendix 
l.c., as cold tap water up to 85 degrees 
F (29 degrees C). 

Some comments to the 1994 FRN 
recommended that the Commission 
revise the definition of cold water. 
Commenters noted that tap water 
temperatures vary across the United 
States, and that such differences can 
cause problems because, in the winter 
in colder parts of the country, detergents 
may not fully activate during a cold 
wash cycle. Other comments suggested 
that the Rule’s definition of hot water 
should be changed. The American 
Association of Textile Chemists and 
Colorists ("AATCC”) commented that 
the temperatures stated in the Appendix 
should be changed to match the AATCC 
definitions, which the AATCC believes 
“more accurately reflect current 
washing machine settings and consumer 
practice.” 85 The AATCC defines “hot” 
as 120 degrees F plus or minus 5 
degrees (49 degrees C plus or minus 3 
degrees). 

The ANPR sought comment on 
whether the Commission should amend 
the Rule to change the definitions of 
“warm” and “hot” water, or to include 


is likely to bleed onto the surrounding fabric A 
company may possess reliable evidence—for 
example, past experience with particular dyes and 
fabrics—that a particular red trim does not bleed 
onto surrounding fabric. In such a case testing of 
the entire garment might not be necessary. 

85 Comment 34 to 1994 FRN. p. 1. 


a new term such as “cool” or 
“lukewarm” in the Appendix. The 
Commission further sought comment on 
whether the Rule should be amended to 
state that care labels recommending 
“cold” wash must define the highest 
acceptable temperature for “cold” on 
the label, and on the benefits and costs 
to consumers and manufacturers of such 
an amendment. 

All eleven comments received in 
response to the ANPR that discussed the 
definitions of cold, warm, and hot water 
favored some change. 86 ATMI stated 
that it is very important that the Rule’s 
water temperature definitions be 
consistent with those used in standard 
test methods developed by AATCC 
because those test methods are used by 
the textile and apparel industries. 87 Six 
of the commenters also supported the 
idea of including a numerical 
temperature on the care label. 88 
Consumers Union, for example, stated 
that consumers need to know the actual 
range of water temperature in which 
they can safely wash their clothes. 

Words such as lukewarm, cold, warm or 
hot serve their purposes only if the 
consumers are aware of safe water 
temperature ranges. Testing laboratories have 
assigned temperature ranges onto each of 
these words. They use these “safe 
temperature ranges” to test products for 
durability to repeated cleaning. Consumers 
should know what these safe water 
temperature ranges are.* 9 

(1) Definition of cold water. As noted, 
six commenters favored the inclusion of 
a numerical temperature on the care 
label. Two others favored a numerical 
temperature when the label 
recommends a "cold” wash. SDA noted 
that in northern locations in winter, 
cold water washes can be as cold as 40 
degrees F and that “the performance of 
all laundry products is seriously 
diminished if they are used in water 
temperatures below 60 degrees F.” 90 
SDA suggested the following care 
instruction, in lieu of “cold”: 

Wash in the warmest available water, not 
to exceed (approximate temperature) degrees 
F. 


88 Bruce Fifield (22); ATMI (41); SDA (43); 
Consumers Union (46); AHAM (51); Maytag 
Appliances (“Maytag”) (53); IFI (56); AAMA (57); 
P&G (60); Ginetex (63); European Commission (64). 
97 ATMI (41) p.l. 

••Fifield (22) p.l; Consumers Union (46) p.l.; 
AHAM (51) p.l: AAMA (57) p.l; European 
Commission (64) p.2; Ginetex (63) p.2. In a meeting 
with staff on August 7,1996, AHAM Indicated that 
it no longer favors this. 

••Consumers Union (46) p.l. 

90 SDA (43) p.2. P&G (60) stated, at p.3, that “all 
detergency and cleaning performance decreases 
substantially in cold water below 70 degrees F.” 


Maytag suggested that a range of 65 to 
80 degrees F should be stated on the 
care label because 

consumers are not aware that water can be 
too cold to activate detergents, thus they 
experience poor cleaning and other laundry 
problems. By incorporating a temperature 
range consumers would know exactly what 
temperatures will provide good results. 91 

P&G said that a national consumer 
study it had conducted showed that 
78% of “cold” loads washed in January 
and February were in temperatures 
below 65 degrees F (with some as low 
as 34 degrees F), and that, year round, 
50% of “cold” loads were washed in 
temperatures below 65 degrees F. 92 

ATMI suggested that “cold” be 
defined consistently with the definition 
specified in AATCC test methods [27 
degrees C plus or minus 3 degrees, or 82 
degrees F plus or minus 5 degrees] and 
with standards developed by the 
American Society for Testing and 
Materials (“ASTM”) (30 degrees C, or 86 
degrees F]. 93 

(2) Definition of warm water. Section 
l.b of the Appendix to the Rule defines 
warm water as 90 to 110 degrees F (32 
to 42 degrees C). Several commenters 
recommended m aintainin g this 
definition, but adding the term 
“lukewarm,” defined as 70 to 89 F (21 
to 31 C). 94 Other commenters opposed 
“lukewarm,” stating that it would be 
confusing to consumers because 
washing machine dials only offer the 
choices of cold, warm, and hot. 95 ATMI 
suggested a definition of 40 degrees C 
plus or minus 5 degrees (104 degrees F 
plus or minus 9 degrees), which it 
described as consistent with the 
definition established by AATCC for use 
in garment testing [41 degrees C plus or 
minus 3 degrees, or 106 degrees F plus 
or minus 5 degrees] and by ASTM in its 
standards [40 degrees C or 104 F]. 

(3) Definition of hot water. 

Maytag stated that “the current 

definition of£ot water as up to 150 
degrees is unrealistic due to scald laws 
in some states” and because new water 
heaters are preset at 120 degrees F. 96 
P&G also noted that hot water heaters 
are now usually preset at 120 F, “much 
less than the 140 degrees F of older 
models.” 97 SDA estimated that “20% of 
today’s homes have hot water heaters 
set at 120-125 F.” 98 Maytag favored 


91 Maytag (53) p.2. 

92 P&G (60) p.3. 

93 ATMI (41) p.2. 

94 SDA (43) p.2; P&G (60) p.2. 

95 ATMI (41) p.l; AHAM (51) p.2; Maytag (53) 
p.l: AAMA (57) p.l. 

"Maytag (53) p. 2; see also SDA (43) p. 2, P&G 

(60) p. 2. 

97 P&G (60) p. 3. 

"SDA (43) p.2. 









Federal Register/ Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


25425 


■efining hot as 120 to 140 degrees F, 
nd SDA and P&G favored defining hot 
s ill to 140 F. ATMI recommended 50 
jgarees C plus or minus 5 degrees C, 
vvhich it described as consistent with 
definitions used by AATCC [49 degrees 
q p] U s or minus 3 degrees C, or 120 F 
0 lus or minus 5 degrees FJ and ASTM 
f 50 C or 122 FI** 

Several commenters argued for the 
addition of “very hot.” 100 P&G noted 
that some American consumers will be 
able to achieve the higher temperatures 
“as new washing machines from Europe 
with onboard heaters enter the U.S.” 101 
IF1 noted that professional laundries can 
achieve the higher temperatures, and 
that the higher temperatures are 
necessary to clean certain types of 
clothes, such as men’s dress shirts. 102 

b. Proposed Amendments and Reasons 
Therefor 

The Commission believes that the 
definition of cold, warm, and hot water 
should be changed because of changes 
in settings on hot water heaters and in 
consumer washing practices in the years 
since the definitions were established. 
The AATCC has changed its definitions, 
which are used in textile testing, to take 
account of these factors, and AATCC 
test methods are used by much of the 
apparel industry. Consequently, the 
Commission believes that the 
definitions in the Rule should be 
changed to be consistent with the 
definitions used by AATCC. The 
Commission proposes changing the 
upper range of temperature definitions 
in the Rule to the upper range of what 
is allowed in tests published by AATCC. 
Thus, the upper range for “cold” would 
be 30 degrees C (86 degrees F); for 
“warm,” 44 degrees C (111 degrees F); 
and for hot, 52 degrees C (125 degrees 
F). 

Finally, the Commission proposes 
adding the term “very hot” to the rule, 
defined consistently with the AATCC 
definition, i.e., with an upper range of 
63 degrees C (145 degrees F). The 
comments indicate that some garments 
do need to be cleaned at temperatures 
higher than 125 degrees F, and that 
some consumers have access to water 
hotter than 125 degrees F, either at 
home or through laundering by 
professional cleaners. The addition of 
the term “very hot,” together with 
appropriate consumer education, should 
give notice to those consumers whose 
hottest water is 120 degrees F that they 
may have to have garments that should 


99 ATMI (41) p. 1. 
,0 ° ATM! (41) p. 1. 
105 P&G (60) p. 3. 
102 P&G (60) p. 3. 


be cleaned in very hot water 
professionally laundered. The 
Commission is aware, however, that the 
term “very hot” may be confusing to 
some consumers because most washing 
ma chin e dials only offer the choices of 
“cold,” “warm,” and "hot.” The 
Commission requests comment on this 
issue, and, in particular, on suggestions 
for methods of consumer education to 
alleviate this problem. 

In addition, some comments indicate 
that consumers need more precise 
information in order to select the 
appropriate temperature setting on their 
washing machines. Consumers may be 
using water that is too cold to activate 
detergents. Similarly, the addition of a 
precise temperature (52 degrees C, 125 
degrees F) after the word “hot” on the 
care label of a garment might give those 
consumers some notice that their hot 
water may be too hot for that garment. 103 
An upper range for "warm” might also 
be helpful to consumers because on 
many machines the dial setting for 
warm simply produces a mixture of hot 
and cold, and if the incoming tap water 
is very cold, the water in the machine 
may be too cold to produce optimal 
cleaning of the clothes being washed. 

The Commission does not believe, 
however, that the solution to these 
problems at this time is to require 
numerical temperatures on care labels. 
Such additional information may not be 
cost-effective because most American 
consumers do not know the temperature 
of the tap water entering their homes or 
the cold or warm water in their washing 
machines. Indeed, some may also lack 
precise information about the 
temperature of the hot water heated by 
their water heaters, and, even those who 
know the upper limit of their hot water 
may not know the temperature of the 
hot water that enters their washing 
machines given the heat loss that occurs 
as water is piped to washing machines. 

Therefore, at this time the 
Commission is not proposing to modify 
the Rule to require that precise 
temperatures be fisted on care labels. 

The Commission is interested, however, 
in non-regulatory solutions to this 
problem. Accordingly, this notice asks 
questions about the possibility of a 
consumer education campaign on these 
issues. The Commission solicits 
comment on the feasibility of such a 
consumer education campaign, the form 


103 Although new water heaters are being set at 
lower temperatures, the comments indicate that 
many homes still have older heaters that produce 
water at 140 degrees F or even hotter. A garment 
that has been tested in water heated to 125 degrees 
F may withstand washing in that temperature 
without damage but nevertheless be damaged by 
water at 140 degrees F. 


it should take, and industry members 
and consumer groups that would be 
interested in participating. Moreover, 
should the comments provide 
additional information about how 
numerical temperatures on care labels 
could be of use to American consumers, 
the Commission is willing to reconsider 
that issue. 

The following changes are proposed 
in the definitions Section of the Rule 
and in the Appendix to the Rule. 

Section 6.(bj(l)(I) of the Rule would 
be modified to read as follows: 

The label must state whether the product 
should be washed by hand or machine. The 
label must also state a water temperature— 
in terms such as cold, warm, hot, or very 
hot—that may be used. However, if the 
regular use of very hot water will not harm 
the product, the label need not mention any 
water temperature. [For example, “Machine 
wash” means very hot, hot, warm or cold 
water can be used.) 

The last sentence of Section 1(d) of 
the Rule would be modified to read as 
follows: 

When no temperature is given, e.g., 

“warm” or “cold,” very hot water up to 145 
degrees F (63 C) can be regularly used. 

“Hot” water would be defined in 
Appendix l.a as ranging from 112 to 125 
degrees F [45 to 52 degrees C], “warm” 
water would be defined in Appendix l.b 
as ranging from 87 to 111 degrees F [31 
to 44 degrees C], and “cold” water 
would be defined in Appendix l.c as 
ranging up to 86 degrees F [30 degrees 
CJ. In addition, “very hot” water would 
be defined in Appendix l.a as ranging 
from 126 to 145 degrees F [53 to 63 
degrees CJ. 

The Commission seeks comment on 
these proposed changes, their 
importance to consumers, the necessity 
for a consumer education campaign to 
help consumers understand and use 
information about water temperature, 
and the form such a campaign might 
take. 104 

Part C— Rulemaking Procedures 

The Commission has determined, 
pursuant to 16 CFR 1.20, to follow the 
procedures set forth in this notice for 
this proceeding. The Commission has 


104 Some companies have already begun to 
educate consumers about these issues. A consumer 
c h a r t prepared by Maytag, with numerical 
definitions for hot, warm, and cold water, states, 
"The clothes washer will not ensure these 
temperatures because the actual water temperatures 
entering the washer are dependent on water heater 
settings and regional water supply temperatures. 

For example, cold water entering the home In the 
northern states during winter may be 40 degrees F 
which is too cold for effective cleaning. The water 
temperature in this situation will need to be 
adjusted by selecting a warm setting or adding some 
hot water to the fill." 







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Federal Register/Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


decided to employ a modified version of 
the rulemaking procedures specified in 
Section 1.13 of the Commission’s Rules 
of Practice. The proceeding will have a 
single Notice of Proposed Rulemaking, 
and disputed issues will not be 
designated. 

The Commission will hold a public 
workshop conference to discuss the 
issues raised by this NPR. Moreover, if 
comments in response to this NPR 
request hearings with cross-examination 
and rebuttal submissions, as specified in 
Section 18(c) of the Federal Trade 
Commission Act, 15 U.S.C. 57a(c), the 
Commission will also hold such 
hearings. After the public workshop, the 
Commission will publish a notice in the 
Federal Register stating whether 
hearings will be held in this matter, and, 
if so, the time and place of hearings and 
instructions for those desiring to present 
testimony or engage in cross- 
examination of witnesses. 

Part D—Section-By-Section Description 
of Proposed Amendments 

1. Amendments Relating to Required or 
Permissible Care Instructions 

The Commission proposes to amend 
section 423.1, “Definitions” to include 
the foliowring definition: 

(h) Professional wet cleaning means a 
system of cleaning by means of 
equipment consisting of a computer- 
controlled washer and dryer, wet 
cleaning software, and biodegradable 
chemicals specifically formulated to 
safely wet clean wool, silk, rayon, and 
other natural and man-made fibers. The 
washer uses a frequency-controlled 
motor, which allows the computer to 
control precisely the degree of 
mechanical action imposed on the 
garments by the wet cleaning process. 
The computer also controls time, fluid 
levels, temperatures, extraction, 
chemical injection, drum rotation, and 
extraction parameters. The dryer 
incorporates a residual moisture (or 
humidity) control to prevent overdrying 
of delicate garments. The wet cleaning 
chemicals are formulated from 
constituent chemicals on the EPA’s 
public inventory of approved chemicals 
pursuant to the Toxic Substances 
Control Act. 

The Commission proposes to amend 
section 423.6(b) of the Rule to read as 
follows: 

(b) Care labels must state what regular 
care is needed for the ordinary use of 
the product. In general, labels for textile 
wearing apparel must have either a 
washing instruction or a dry cleaning 
instruction. If an item of textile wearing 
apparel can be successfully washed and 
finished by a consumer at home, the 


label must provide an instruction for 
washing. If a washing instruction is not 
included, or if washing is warned 
against, the manufacturer or importer 
must establish a reasonable basis for 
warning that the item cannot be washed 
and adequately finished at home, by 
possessing, prior to sale, evidence of the 
type described in paragraph (c) of this 
section. If a washing instruction is 
included, it must comply with the 
requirements set forth in paragraph 
(b)(1) of this section. If a dry cleaning 
instruction is included, it must comply 
with the requirements set forth in 
paragraph (b)(2) of this section. An 
instruction for professional wet cleaning 
may also be given. If an instruction for 
professional wet cleaning is given, it 
must comply with the requirements set 
forth in paragraph (b)(3) of this section. 
If the product cannot be cleaned by any 
available cleaning method \yithout 
being harmed, the label must so state. 
[For example, if a product would be 
harmed both by washing and by dry 
cleaning, the label might say, “Do not 
wash—do not dry clean,” or “Cannot be 
successfully cleaned.”! The instructions 
for washing, dry cleaning, and 
professional wet cleaning are as follows: 

It should be noted that, in addition to 
the additions to section (b) noted in 
bold, the following sentence has been 
deleted: “If either washing or dry 
cleaning can be used on the product, the 
label need have only one of these 
instructions.” 

The Commission also proposes to add 
the following subsection to section (b). 

(3) Professional wet cleaning. 

If a professional wet cleaning 
instruction is included on the label, it 
must state at least one type of 
professional wet cleaning equipment 
that may be used to clean the garment. 
However, if the product can be 
successfully cleaned by all 
commercially available types of 
professional wet cleaning equipment, 
the label need not mention any type of 
wet cleaning equipment. A care label 
that recommends professional wet 
cleaning must list the fiber content of 
the garment and must recommend one 
other method of cleaning, such as 
washing or drycleaning, or must warn 
that the garment cannot be washed or 
drycleaned if such is the case. 

2. Amendment of Reasonable Basis 
Section 

The Commission proposes to amend 
§ 423.6(c)(3) as follows: 

(c) A manufacturer or importer must 
establish a reasonable basis for care 
information by possessing prior to sale: 

(3) Reliable evidence, nice that 
described in paragraph (c)(1) or (2) of 


this section, for each component part of 
the product in conjunction with reliable 
evidence for the garment as a whole; 

3. Amendment of Definitions of Water 
Temperatures 

The Commission proposes to amend 
the last se’ntence of § 423.1(d) of the 
Rule to read as follows: 

When no temperature is given, e.g., 
“warm” or “cold,” very hot water up to 
145 degrees F (63 C) can be regularly 
used. 

The Commission proposes to amend 
section 423.6(b)(l)(I) of the Rule to read 
as follows: 

The label must state whether the 
product should be washed by hand or 
machine. The label must also state a 
water temperature—in terms such as 
cold, warm, hot, or very hot—that may 
be used. However, if the regular use of 
very hot water will not harm the 
product, the label need not mention any 
water temperature. [For example, 
“Machine wash” means very hot, hot, 
warm or cold water can be used.) 

The Commission proposes that 
Appendix A.l.a-l.c be modified to read 
as follows: 

1. Washing. Machine Methods: 

a. Machine wash—a process by which 
soil may be removed from products or 
specimens through the use of water, 
detergent, or soap, agitation, and a 
machine designed for this purpose. 

When no temperature is given, e.g., 
“warm” or “cold,” very hot water up to 
145 degrees F (63 degrees C) can be 
regularly used. 

b. Hot—initial water temperature 
ranging from 112 to 125 degrees F [45 
to 52 degrees C). 

c. Warm—initial water temperature 
ranging from 87 to 111 degrees F [31 to 
44 degrees C). 

d. Cold—initial water temperature up 
to 86 degrees F [30 degrees CJ. 

Part E—Regulatory Analysis and 
Regulatory Flexibility Act 
Requirements 

Under section 22 of the FTC Act, 15 
U.S.C. 57b, the Commission must issue 
a preliminary regulatory analysis for a 
proceeding to amend a rule only when 
it (1) estimates that the amendment will 
have an annual effect on the national 
economy of $100,000,000 or more; (2) 
estimates that the amendment will 
cause a substantial change in the cost or 
price of certain categories of goods or 
services; or (3) otherwise determines 
that the amendment will have a 
significant effect upon covered entities 
or upon consumers. The Commission 
has preliminarily determined that the 
proposed amendments to the Rule will 
not have such effects on the national 







Federal Register/Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


25427 


on 0 my, on the cost of textile wearing 
00 are 1 or piece goods, or on covered 
businesses or consumers. The 
Commission, however, requests 
,-nmment on these effects. 

C The Regulatory Flexibility Act 
(“RFA"). 5 U.S.C. 601-12, requires that 
the agency conduct an analysis of the 
anticipated economic impact of the 
proposed amendments on small 
businesses. 105 The purpose of a 
regulatory flexibility analysis is to 
ensure that the agency considers impact 
0 n small entities and examines 
regulatory alternatives that could 
achieve the regulatory purpose while 
minimizing burdens on small entities. 
Section 605 of the RFA, 5 U.S.C. 605, 
provides that such an analysis is not 
required if the agency head certifies that 
the regulatory action will not have a 
significant economic impact on a 
substantial number of small entities. 

Because the Care Labeling Rule covers 
manufacturers and importers of textile 
wearing apparel and certain piece 
goods, the Commission believes that any 
amendments to the Rule may affect a 
substantial number of small businesses. 
For example, unpublished data 
prepared by the U.S. Census Bureau 
under contract to the Small Business 
Administration (“SBA”) show there are 
some 288 manufacturers of men’s and 
boys” suits and coats (SIC Code 2311), 
more than 75% of which qualify as 
small businesses under applicable SBA 
size standards^ 106 There are more than 
1,000 establishments manufacturing 
women’s and misses’ suits, skirts, and 
coats (SIC Code 2337), most of which 
are small businesses. Other small 
businesses are likely covered by the 
Rule. 

Nevertheless, the proposed 
amendments would not appear to have 
a significant economic impact upon 
such entities. The amendment to allow 
for labeling for professional wet 
cleaning simply provides an option that 
can be taken advantage of by businesses 
if they wish. The amendment to require 
that garments that can be safely washed 
at home be labeled for home washing 
will also not add significantly to the 
cost of compliance for most businesses 
because businesses will still only be 
required to provide instructions for one 
method of cleaning. It is true that those 
businesses that currently label garments 
for dry cleaning without investigating 


105 The RFA addresses the impact of rules on 
“small entities.” defined as "small businesses.” 
“small businesses,” “small governmental entities.” 
and “small [not-for-profit] organizations." 5 U.S.C. 
601. The Rule does not apply to the latter two types 
of entities. 

,os SBA’s revised small business size standards 
are published at 61 FR 3280 (Jan. 31.1996). 


whether they can be washed at home 
would have to make that determination. 
Most businesses, however, obtain 
information about the washability of the 
components of their garments from the 
sources of those components, and in 
many cases this simple inquiry will 
provide a reasonable basis for either a 
dry clean instruction or a home washing 
instruction. Although some businesses 
may have to engage in additional efforts, 
such as testing, to make this 
determination, it does not seem likely 
that this will be the case for most 
businesses. The Rule specifies that a 
reasonable basis can consist of various 
types of reliable evidence other than 
testing, and most businesses do not 
routinely test each garment style they 
manufacture or import. Nevertheless, 
the Commission specifically seeks 
comment regarding these amendments’ 
potential impact on small businesses. 

In addition, the Co mmi ssion is 
proposing to amend one category of the 
types of evidence that can constitute a 
reasonable basis, i.e., evidence of testing 
of components of the garment, to clarify 
that the manufacturer or importer must 
also have reliable evidence that the 
garment as a whole can be cleaned as 
directed without damage. The 
Commission specifically has indicated 
that testing of the garment as a whole is 
not required in all instances, however; 
what is required is an evaluation of 
whether the garment as a whole can be 
successfully cleaned without damage in 
the manner recommended on the care 
label. The Commission views the 
amendment of this section of the Rule 
as simply a clarification of the fact that 
the manufacturer or importer must have 
a reasonable basis for the garment as a 
whole, not simply for the separate 
components. 

Based on available information, the 
Commission certifies that amending the 
Care Labeling Rule as proposed will not 
have a significant economic impact on 
a substantial number of small 
businesses. To ensure that no significant 
economic impact is being overlooked, 
however, the Commission requests 
comments on this issue. The 
Commission also seeks comments on 
possible alternatives to the proposed 
amendments to accomplish the stated 
objectives. After reviewing any 
comments received, the Commission 
will determine whether a final 
regulatory flexibility analysis is 
appropriate. 

Part F—Paperwork Reduction Act 

The Rule contain various information 
collection requirements for which the 
Commission has obtained clearance 
under the Paperwork Reduction Act, 44 


U.S.C. 3501 et seq.. Office of 
Management and Budget Control 
Number 3084-0103. As noted above, the 
Rule requires manufacturers and 
importers of textile wearing apparel to 
attach a permanent care label to all 
covered items and requires 
manufacturers and importers of piece 
goods used to make textile clothing to 
provide the same care information on 
the end of each bolt or roll of fabric. 
These requirements relate to the 
accurate disclosure of care instructions 
for textile wearing apparel. Although 
the Rule also requires manufacturers 
and importers to base their care 
instructions on reliable evidence, it does 
not contain any explicit recordkeeping 
requirements. 

The Rule also provides a procedure 
whereby a member of the industry may 
petition the Commission for an 
exemption for products that are claimed 
to be harmed in appearance by the 
requirement for a permanent label, but 
only one petition, subsequently 
withdrawn, has been filed in recent 
years. A Notice soliciting public 
comment on extending the clearance for 
the Rule through December 31,1999, 
was published in the Federal Register 
on August 26, 1996, 61 FR 43764. OMB 
has extended the clearance until 
December 31,1999. 

The proposed amendments would not 
increase the paperwork burden 
associated with these paperwork 
requirements. The Commission’s 
proposed amendment regarding 
professional wet cleaning does not 
increase the paperwork burden because 
it is optional. Businesses that do not 
believe'it is beneficial to label for 
professional wet cleaning are not 
required to do so. The proposed 
amendment of the Rule to require that 
any garment or fabric that can be 
washed at home be so labeled will not 
increase the burden for businesses 
because they will still need to label for 
only one method of cleaning. 

Tne proposed amendment to change 
the numerical definition of the words 
“hot,” warm,” or “cold,” when they 
appear on care labels, and to add the 
term “very hot,” will not add to the 
burden for businesses because they are 
already required to indicate the 
temperature in words and to have a 
reasonable basis for whatever water 
temperature they recommend. 

Moreover, businesses are not burdened 
with determining what temperature 
should accompany the words “very 
hot,” “hot,” “warm,” or “cold”; the 
proposed amendment would provide 
the numerical temperature that should 
accompany each term. OMB regulations 
provide, at 5 CFR 1320.3(c)(2), that “the 






25428 


Federal Register /Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules 


public disclosure of information 
originally supplied by the Federal 
government to the recipient for the 
purpose of disclosure to the public is 
not included within (the definition of 
collection of information.]’' 

Thus, the Commission concludes that 
the proposed amendments would not 
increase the paperwork burden 
associated with compliance with the 
Rule. To ensure that no significant 
paperwork burden is being overlooked, 
however, the Commission requests 
comments on this issue. 

Part G—Request for Comments 

Members of the public are invited to 
comment on any issues or concerns they 
believe are relevant or appropriate to the 
Commission’s consideration of 
proposed amendments to the Care 
Labeling Rule. The Commission 
requests that factual data upon which 
the comments are based be submitted 
with the comments. In addition to the 
issues raised above, the Commission 
solicits public comment on the costs 
and benefits to industry members and 
consumers of each of the proposals as 
well as the specific questions identified 
below. These questions are designed to 
assist the public and should not be 
construed as a limitation on the issues 
on which public comment may be 
submitted. 

Questions 

A. Requiring Instructions for Cleaning in 
Water 

(1) Is there empirical evidence 
regarding whether consumers interpret a 
“dry clean” instruction to mean that a 
garment cannot be washed? 

(2) How many domestic businesses 
provide professional wet cleaning, as 
defined in Part D.l. above, to the public 
on a regular basis? 

(3) Should the Rule provide that, if an 
instruction for professional wet cleaning 
is provided, no other instruction need 
be given, or should a professional wet 
cleaning instruction only be allowed 
along with another cleaning instruction? 

B. The Reasonable Basis Requirement of 
the Rule 

(4) Would the amendment of Section 
423.6(c)(3) of the Rule, which provides 
that a reasonable basis can consist of 
reliable evidence that each component 
of the garment can be cleaned according 
to the care instructions, to state, 
additionally, that a manufacturer or 
importer must possess a reasonable 
basis for the garment as a whole, clarify 
the reasonable basis requirements? Is 
any additional clarification needed? 


C. Definitions of Water Temperatures 

(5) How can consumers best be made 
aware of the approximate water 
temperatures in which they ran safely 
and effectively wash their clo thin g? 
How can consumers best be made aware 
of how these temperatures correlate to 
the descriptors "hot,” "warm,” and 
“cold”? Do consumers need to 
determine the actual or approximate 
water temperature in their washing 
machines when they select “hofi” 
"warm,” and "cold” on their washing 
machine dials, and, if so, how could 
they easily and practically do this ? 
Could consumers use this information 
to select the optimal temperature offered 
by their w ashin g ma chin es for clothes 
labeled for "hot,” “warm,” or "cold” 
washing? 

(6) Would consumers understand an 
instruction to use “very hot” water? 
Could consumers use this information 
either to select the optimal temperature 
offered by their washing m achin es for 
clothes labeled for “very hot” washing 
or to determine that such clothes should 
be washed by a professional cleaner? 

Authority; Section 18(d)(2)(B) of the 
Federal Trade Commission Act, 15 U.S.C. 
57a(d)(2)(B). 

List of Subjects in 16 CFR Part 423 

Care labeling of textile wearing 
apparel and certain piece goods; Trade 
practices. 

By direction of the Commission, 
Commissioner Azcuenaga not participating. 
Donald S. Clark, 

Secretary. 

[FR Doc 98-12233 Filed S-7-98; 8:45 am] 

BILLING CODE 87KM31-P 


DEPARTMENT OF THE INTERIOR 

Office of Surface Mining Reclamation 
and Enforcement 

30 CFR Part 934 

(SPATS No. ND-037-FOR, Amendment No. 
XXVI] 

North Dakota Regulatory Program 

AGENCY: Office of Surface Mining 
Reclamation and Enforcement, Interior. 
ACTION: Proposed rule; public comment 
period and opportunity for public 
hearing on proposed amendment. 

SUMMARY: The Office of Surface Mining 
Reclamation and Enforcement (OSM) is 
announcing receipt of a proposed 
amendment to the North Dakota 
regulatory program (hereinafter, the 
“North Dakota program”) under the 
Surface Mining Control and 


Reclamation Act of 1977 (SMCRA). The 
proposed amendment consists of 
proposed changes to North Dakota’s 
revegetation policy document, 
"Standards for Evaluation of 
Revegetation Success and 
Recommended Procedures for Pre- and 
Postmining Vegetation Assessments.” 

The changes pertain to (1) prime 
farmland woodland productivity 
standards, (2) woodland cover 
standards, (3) wetland standards, (4) 
woodland and shelterbelt standards for 
recreational lands, and (5) methods for 
sampling woodland cover. The 
amendment is intended to revise the 
North Dakota program to be consistent 
with SMCRA and the Federal 
regulations, and to improve operational 
efficiency. 

DATES: Written comments must be 
received by 4:00 pun., m.d.t., June 8, 
1998. If requested, a public hearing on 
the proposed amendment will be held 
on June 2,1998. Requests to present oral 
testimony at the hearing must be 
received by 4:00 p.m., m.d.t. on May 26, 
1998. 

ADDRESSES: Written comments should 
be mailed or hand delivered to Guy 
Padgett at the address listed below. 

Copies of the North Dakota program, 
the proposed amendment, and all 
written comments received in response 
to this document will be available for 
public review at the addresses fisted 
below during normal business hours, 
Monday through Friday, excluding 
holidays. Each requester may receive 
one free copy of the proposed 
amendment by contacting OSM’s Casper 
Field Office. 

Guy Padgett, Director, Casper Field 
Office, Office of Surface Minin g 
Reclamation and Enforcement, 100 
East “B” Street, Federal Building, 
Room 2128, Casper, Wyoming 82601- 
1918, Telephone: 307/261-6550 
James R. Deutsch, Director, Reclamation 
Division, Public Service Commission, 
State Capitol—600 E. Boulevard, 
Bismarck, North Dakota 58505-0480, 
Telephone: 701/328-2400. 

FOR FURTHER INFORMATION CONTACT: 

Guy Padgett, Telephone: 307/261-6550; 
Internet: GPadgettOSMRE.GOV 
SUPPLEMENTARY INFORMATION: 

I. Background on the North Dakota 
Program 

On December 15,1980, the Secretary 
of the Interior conditionally approved 
the North Dakota program. General 
background information on the North 
Dakota program, including the 
Secretary’s findings, the disposition of 
comments, and conditions of approval 
of the North Dakota program can be 

















GARMENT AND TEXTILE CARE: AN EYE TO THE FUTURE: March 31-April 2 


DRAFT PROPOSALS BY FTC STAFF FOR GATHERING MORE DATA FROM DRY 

CLEANERS ABOUT GARMENTS WITH INCORRECT CARE INSTRUCTIONS 

Tip of the iceberg: At the workshops in January, 1998 sponsored by EPA's Design 
for the Environment/Garment and Textile Care Program, there was much discussion of the 
need for a good database of the safety and effectiveness of various cleaning methods on 
various types of textiles and garments. The staff of the Federal Trade Commission (FTC), 
which is responsible for enforcing and updating the Care Labeling Rule, also believes the 
compilation of a large database about the effects of various cleaning methods -- new and 
old -- is very important. Our primary goal is to see that care labels provide correct 
information about methods by which a garment can be safely cleaned. The International 
Fabricare Institute (IFI) has been computerizing data about garments that were damaged in 
cleaning for more than ten years, and IFI has shared this data with FTC staff, which has 
used this data to locate targets for investigation. In appropriate instances, the Commission 
has brought actions for civil penalties against garment manufacturers and importers for 
violating the Care Labeling Rule. IFI has always asserted, however, that the data it provides 
is only the "tip of the iceberg." 

More of the iceberg: If more of the iceberg could be revealed, several thing could 
happen. If the data is sent to FTC, staff could bring more cases against garment 
manufacturers and importers who attach incorrect care labels to their garments, causing 
problems for consumers and cleaners alike. If the data is sent to AAMA, garments 
manufacturers and importers could benefit by using it, along with other information, when 
deciding what care instructions to recommend. Data about "problem garments" would 
include data about both new and old cleaning techniques, and would help manufacturers 
and importers make a rational decision about what care instructions to recommend. 

A plan for gathering data and taking action: This goal of gathering more data 
about "problem" garments overlaps with the goals expressed at the January workshops by 
cleaners and manufacturers alike. Part I below quotes from relevant parts of the Working 
Drafts from the work groups. In Part II below, we suggest several ways of collecting a large 
database of information about garments that were damaged when cleaned. We also suggest 
various uses that can be made of this database. We hope this will help stimulate ideas at 
this conference. 

I. NEEDS EXPRESSED IN THE JANUARY WORKSHOPS 

A. THE DRY CLEANING WORKGROUP MEETING: January 12. 1998 

GOAL 1: Develop standardized methods and objective criteria for the side-by-side 
evaluation of new cleaning technologies, identifying and listing the limitations of each in a 
matrix or database listing performance for cleaning systems and fabrics, (p.5) 

1. Issue 5: Need for Database of Problem Garments 

• Cleaners need a way to "look up" whether or not a particular garment can be 
cleaned using a particular cleaning method, (p.5) 







A pp roach es/Strategies: 

• Develop a cleaning method performance matrix. . . . The reason for this is to see 
where solvents are performing well and where they are performing poorly. . . . For 
a given process, problems should be highlighted, (p.6) 

GOAL 7: Persuade the garment industry to adopt more accurate care labels, (p. 14) 

Issue 1: Damaged garments are a liability for drycleaners. 

Approach es/Strategies 

• A more comprehensive knowledge base for garment care needs to be accessible, 
so that when testing on garments is performed, there is more solid ground for 
assessing the cleanability of the garment, (p. 15) 


These goals are consistent with the needs of FTC staff for 
more data in order to assure the accuracy of care labels by bringing 
suit, where appropriate, for civil penalties for violation of the Care 
Labeling Rule, and for helping garment manufacturers and importers 
devise correct care labels. Indeed, this Workgroup noted the 
following barrier to change, which could be reduced by the 
increased enforcement additional data would allow. 

Barriers for Change: 

• The garment industry's goal is to sell their garments, not to provide care for them. 
There is no real incentive in place, (p. 15) 

B. THE SCIENCE AND TECHNOLOGY WORKGROUP: January 13,1998 

GOAL #1: Test each alterative technology "system” using standardized testing protocols 
and produce a "matrix" which compares the technologies by standardized measures in 
order to provide guidance to dry cleaners and further scientific understanding, (p.4) 
Approaches/Strategies: 

• Conduct both controlled laboratory testing (for uniformity of results) and on-site 
testing (for "real world" practicality). Some participants thought that on-site 
testing should be conducted by dry cleaners, others by independent researchers. 
(p.5) 

GOAL #3: Change care labels to recognize alternative cleaning technologies, (p.8) 
Approach es/Strategies: 

• Make the matrix (see goal #1) available to apparel manufacturers as input into 
care label development process, (p.8) 

These goals are also consistent with the goals of FTC staff. If a 
large database of "problem garments" is compiled and shared with 


2 


garment manufacturers and importers, they will be able to use that 
"real world" information to recommend safe care procedures. 

C. THE TEXTILE WORKGROUP: January 14, 1998 

GOAL #4: Identify fibers and fabrics that cause cleaning problems with ACP [Alternative 

Cleaning Processes] technologies and communicate that information to the textile industry. 

(P-12) 

App roach es/Strategies: 

• Collect and formally document problem fiber/fabric information vis-a-vis 
application of new ACPs (strive to collect as much information as possible). 

A database should be developed. 

• Information on problems for dry cleaners associated with specific fibers, 
fabrics, and apparel is available from sources such as the local small claims 
courts, the Better Business Bureau, the International Fabricare Institute 
(IFI), and the Neighborhood Cleaners Association International (NCAI). 
(P-12) 

GOAL #5: Create and implement a method of ongoing communication between the textile 

industry and the fabricare industry, (p.14) 

Key Issues: 

• Close communication between the textile, apparel, sundries, and fabricare 
industries is necessary in order to facilitate the 
development/commercialization/refinement of new ACPs. Also this 
communication link should provide information on problem fibers and 
fabrics. This information will help textile and apparel manufacturers to 
produce products that can be readily cleaned with the new ACP technologies. 
(P-14) 

Goal I lists many of the sources of data which we suggest using in 
Part II below. All of these sources receive complaints about 
damaged garments, but some of them do not currently report it, as 
is discussed below. Goal 5 is relevant because the database that is 
gathered can be shared with the textile industry. 


II. PROPOSED METHODS OF GATHERING DATA 

A. CREATE A METHOD FOR ELECTRONIC FILING OF COMPLAINTS 

1. Create an electronic form that can be filled in on-line and that is compatible with 
an existing data-base software package. [FTC may be able do this.] A paper form could 
also be used, but would probably be more costly to collect and evaluate data from paper. 



2. Create a mailbox for filing the electronic form. [FTC could do this, if that is 
most efficient and desirable to all the parties. Or the data could be sent directly to the 
source(s) described in point 4. below.] 

3. Publicize existence of form and mailbox to cleaners [via existing cleaner chat 
rooms, via trade associations, etc.] 

4. Automatically forward the data to an appropriate party for analysis, [e.g., a 
university textile professor and/or students - grant might be necessary.] 

5. Party that evaluates the data could forward it to FTC. FTC could use it to 
investigate and bring some cases [in the most egregious cases], but could also share the 
data with EPA, which could provide it to experts who are evaluating the effectiveness of 
various cleaning methods. 

6. EPA and FTC could share data with AAMA. 

7. AAMA evaluates data in terms of combinations of trim, fabric, etc., which have 
been damaged when cleaned and passes this info along to its members in general form. 

8. Either FTC or AAMA notifies specific firms that have a high number of 
complaints (but not so high that they have been sued) of the existence of the complaints. 

B. HELP TRADE ASSOCIATIONS COMPUTERIZE EXISTING DATA 


1. Provide personnel to help IFI computerize all relevant data. [Grant would be 
necessary.] 

2. Provide personnel to help NCA begin computerizing data. [Grant would be 
necessary.] 

3. Provide help to state associations that are not part of IFI or NCA (e.g., Calif., 
Dakota). Some such associations may already be collecting data, and others may not. 
[Grant might be nec.] 

4. Send all such data to FTC (as IFI is currently doing). FTC could share such data 
with all the above-listed sources (i.e., textile professor/students who are analyzing data, 
EPA, AAMA). 

C. HELP BETTER BUS. BUREAUS COMPUTERIZE EXISTING DATA 

1. If data is not already computerized in a useful form, provide personnel to help 
computerize all relevant data. [Grant might be necessary.] 


4 





2. Send all such data to FTC (as IFI is currently doing). FTC could share such data 
with all the above-listed sources (i.e., textile professor/students who are analyzing data, 
EPA, AAMA). 

D. HELP SMALL CLAIMS COURTS COMPUTERIZE EXISTING DATA 

1. Ask courts if they have a large number of claims involving cleaners. [Use 
Internet list serve.] 

2. For courts that do have a large number of such claims, ask if they would be 
interested in sharing their data (and probably in collecting some data they do not currently 
collect.) 

3. Send all such data to FTC (as IFI is currently doing). FTC could share such data 
with all the above-listed sources (i.e., textile professor/students who are analyzing data, 

EPA, AAMA). 


5 



Fabricare Industry Perspective 


Jackie Stephens 
International Fabricare Institute 


Good morning. 

One of the major concerns of the fabricare industry continues to be proper care labeling. The care 
label on a garment implies that the garment can be cleaned and refurbished by the care process that is 
listed. When a garment is accepted at the counter, the drycleaner and the drycleaner's customer have a 
certain level of expectation regarding the serviceability of that garment to that care process. Frequently, 
however, the drycleaner experiences significant shade changes, color loss, staining from dye migration, 
loss of designs, and loss of trim in the cleaning process. 

Many of these garments are submitted to EFI's Garment Analysis Laboratory for a fair assessment 
of the damage and to determine who is responsible for the damage that is caused in the cleaning process. 
The IFI database, as Connie mentioned, has been in use since 1988. We have compiled information from 
garments received for testing through the analysis laboratory. The garments are categorized in terms of 
responsibility for the type of damage that we see in the laboratory as determined by the IFI analyst. The 
main categories include manufacturer causes, consumer responsibility, responsibility caused by the dry 
cleaner, and the unknown category representing garments with no obvious damage. 

In 1997, we analyzed over 20,000 garments in the Garment Analysis Laboratory. The problems 
that were attributed to manufacturer responsibility represent around 39 percent of the total problems 
submitted to the laboratory; consumer-caused damage represented 35 percent of the problems. The 
cleaner caused around 12 percent of the problems and again we have "unknown", or no obvious damage 
to the garments, which was 4 percent. Garments submitted for restoration only represented 9 percent of 
the problems. 

Problems from color loss represent 45 percent of that total number. One of the most common 
problems being color loss in drycleaning, solvent soluble dye, or loss of pnnt in drycleaning. In the 
category of the manufacturer-caused damage, the 39 percent category, the most common problems that 
we see are from color loss. 

Garment defects and garment construction problems represent about 16 percent of that total and 
problems with trim are around 5 percent. This can be caused by a loss of trim, beads melting, loss of 
sequins, et cetera. That is around 5 percent of that total manufacturing problem. 

An analysis of the trends since 1989 shows that the manufacturing problems have been 
consistently in the 35 to 40 percent range for that 10 year period. Actually, from 1989 to year to date 
1988, they have been in the 35 to 40 percent category. 

The majority of the problems that we see in the laboratory are overwhelmingly in women's wear. 
Women's wear represents 70 to 75 percent of the total problems that we see in the manufacturing 
category. Men's wear falls between 17 and 23 percent. Problems with unisex and children's garments 
average around 5 to 8 percent. 


110 


An analysis of the data for the last 3 years shows that U.S.-made goods have consistently 
contributed to 25 to 36 percent of the problems that we see in the laboratory. Seven to 10 percent have 
originated in Hong Kong and 6 to 9 percent in Korea. Other countries pose around 3 to 4 percent of the 
problem that we see in the laboratory. 

Acetate and acetate blend fibers have contributed to 13 to 19 percent of the problems since 1995; 
cotton and cotton blend fibers, 13 to 20 percent of the problems; polyester, 10 to 12 percent; and silk and 
silk blend fabrics, 11 to 13. The "other" category represents fibers with less than 8 percent of the 
problem. 

We realize that this database is limited to the problems that are submitted to the Garment 
Analysis Laboratory and does not represent the magnitude of problems that many drycleaners, retailers, 
and consumers face daily. However, we feel that it has been a very useful resource in developing 
educational and training materials for our industry, working with fiber and apparel manufacturers, and 
testing and performance criteria for fabrics and garments, as well as contributing to the type of dialogue 
that we should experience today. 


Ill 


^ International Fabricare Institute 

srs The Association of Professional Drycleaners ami Launderers 


US EPA DfE GARMENT AND TEXTILE CARE STRATEGY DEVELOPMENT PARTNERSHIP 

DRYCLEANENG WORKGROUP 

Co-chairs: Bill Fisher, IFI & Bill Seitz, NCA-I 
Monday, January 12,1998 


A STARTING POINT FOR DISCUSSION: LONG TERM STRATEGIC GOALS 

As we begin the Drycleaning Workgroup discussions, the following three points may help give a 
jumping-off point to begin discussions on long-term strategic goals within the context of the Design 
for the Environment Program and our industry's continuing environmental responsibility. 

The suggestions given here are not intended to be either exclusive or limiting on the discussions of 
the Drycleaning Workgroup, but will hopefully provide a framework and focused areas to help start 
our discussions. 


Bill Fisher 


A. How Should New Technologies and Alternative Processes be Evaluated ? 

The most critical issue facing the perchloroethylene drycleaning industry in trying to evaluate 
a new technology can be summarized in a very basic question: "Will this process readily, 
easily, and satisfactorily handle the garments I currently receive for drycleaning?" 

A simple question—but one that has highly complex answers. No single process or cleaning 
medium is "perfect," in the sense that no single process can readily and satisfactorily handle 
all types of garments and household items (including both textile and non-textile items). 

In any discussion of other processes, the first factor that must be recognized is that there are 
trade-offs in performance characteristics between each process. The key to assessing the 
adequacy of a process—as a result—becomes not how good it is, but whether there are one 
(or several) critical performance areas where the process is effectively ruled out as a substitute 
or replacement for perchloroethylene systems. 


12251 Tech Road Silver Spring, Maryland 20904 Z (301)622-1900 Z FAX (301) 236-9320 








Compounding this problem, the decision as to whether there are characteristics which make 
a process unacceptable is a highly subjective one—and one for which there will be, at times, 
widely differing opinions and viewpoints. 

There is a potential way, however, to drive the evaluation process towards being as objective 
as possible. This would involve development of a matrix of properties and performance 
criteria, so that existing and new processes can be evaluated on a side-by-side basis as much 
as is possible. The development and use of such a matrix achieves two major objectives: 
First, it immediately identifies when information is not available for a process—and for which 
answers must be found before a true evaluation can be made. Second, it provides a method 
for evaluation as to whether one (or several) major characteristics of a process are sufficiently 
unacceptable so as to eliminate consideration of that process as a realistic substitute for 
perchloroethylene systems. 

A very rough draft of this concept is attached. If the need to establish minimal acceptable 
performance criteria for new processes is a strategic goal which should be pursued, 
development and completion of the matrix would of necessity be shared by the Dry cleaning 
Workgroup and the Technology Workgroup—and possibly other workgroups as well. 


What Are the Economics of New Proccssess, and Are They Affordable? 

If the first "simple” question is whether an alternative process can satisfactorily clean clothes 
that are that currently drycleaned, then the second key question is "Can I afford this system?" 


Again, a simple question to ask, but one which is difficult to answer. The question of 
affordability is comprised of several key issues: First, how much does the system cost—is the 
price low enough for me to able to purchase it? Second, what is my own current financial 
situation, and am I still paying for new perc equipment? Third, where am I going to get the 
money to pay for this equipment? 

The drycleaning industry in the United States is made up of approximately 30,000 operating 
plant establishments, with approximately one-third of those plants owned by Korean 
entrepreneurs who may not have full access to traditional financing avenues. Additionally, 
the industry is made up of plants of widely-differing sizes, so that what is affordable to one 
operation may be out of the question for another. 

The attached table and graph, taken from the U.S. Census of Service Industries data for retail 
drycleaning plants (SIC 7216) for 1992, gives a better appreciation for the range of average 
receipts as they exist today in our industry. The small size of a large portion of our industry 
leads to the question of whether a regulatory policy should be considered acceptable (by 
regulators_and/or industry members) if a major portion of the industry is not able to afford a 
new process. 



In searching for answers to the questions of affordability of new processes for the drycleaning 
industry, issues that need to be addressed include the potential availability of guaranteed low- 
cost loans, business tax credits, accelerated depreciation and/or other innovative solutions. 


C. What Can be Done Now to Reduce Perc Consumption, Without Equipment 

Replacement? 

Arguably, the industry needs to continue in the direction of reducing consumption and usage 
of perchloroethylene, while answers are found to the dual questions of the viability of 
alternative processes, and whether the processes are affordable. 

The first questions relative to reduction of perc consumption would apply to plants which 
continue to maintain perc-only operations. Specifically, what can be done on the equipment 
side to reduce consumption, and what can be done on the operational end and training sides 
to reduce consumption? 

The second questions are relative to what can be done to reduce perc consumption by using 
other systems as supplemental or auxiliary processes to handle a portion of the articles 
received for cleaning. Specifically, what supplemental processes are satisfactory and 
affordable, so that they could be used to handle a portion of the garments which are currently 
drycleaned? 


In summary, the three broad areas given above may provide a framework—or may generate 
discussion—helping us to move towards the development of strategic goals related to evaluating the 
technical feasibility and the economic affordability of potential alternative processes, while allowing 
and encouraging the industry to continue to increase its environmental responsibility. 




PERFORMANCE PARAMETERS FOR PROCESSES/FLUIDS FOR THE CLEANING OF APPAREL fir RELATED 

Based on total Process industwy surfactants and Detergents 


OMfTMinwrw OwcumatOM Pu mmom ma Ohlt 

PQCPAItgP IT IFl / januaitt 9. 1 9»6 


I 







BlfDtMt 

Comm 

Prof 



Performance Cnteoa 

PeTC 

Petrol 

Pvrvei 

C07 

Mom* Wain Wash 

Wiih 

Wetclean 

t-113 

Gasoline Caroon Tet 


A. Cora Charactenspct _ I 

1 Removal o( Water Based 5 o«I» _ G-VG _ G-VG _2_Z_ VO-E _ VO-E _ VG-E _ VO-E _ G-VG _ O-VC _ G-VG : 

2 R»mo»»t of Oil Based Soil* VO-E VG-E "> "> F-VG F-VG C-VG F-VG VG-E VO-E VO-E ~j 

3 Removal of Parocuiata Matter ___| 

4 Residual Odor in Garment* _L_L_ 2 _Z_-_-_-_-_-_ M.L _ 

5 Garment* Easily Doed 


S Surfactant*/Additives Available 


7 Readily Reusable or Diacharqaoie 







B Effect on Fibers/Fabnct 

1 Cotocfaatnoa* 1 

2 Dimensional Change : G-VG G-VG "> ? P-VG P-VO P-VO P-VO G-VG G-VG G-VG 

3 Tensile Strength VO-E VO-E ’ "» P-VO P-VO P-VO P-VO VG-E VO-E VO-E 

4 integrity of Trim Material* 

5 Appearance and Hand 







C. MealtfVSafety/Regulatpry 

1 Flash Point Mona ios-i«r“* ? 7 Nona Nona Nona Non* Non* Non* 

2 Toncity M-H 7 m-M EM 

3 Carcinogenicity 

4 Eaptosive 

S Corrosive 

6 Other Health Concerns 

7 Water Issues 

6 • Air Issues 

$ Contamination issues 

10 Transportation Issues Yes Yes 7 p No No No No Yes Ye* Ye* 

11 Disposal Issues 







D Economic issues 

1 Equipment Costs S30-45K S30-110K ’ ’ <$1K < S1K S6-10K S&-30K S26-60K 

2 Aunliary Equipment Costs 

3 Fluid Costs 

4 Aunliary Chemical Costs 

6 Labor Costs 

7 Operation Costs 






1 Shade Change ASTM standard of a minimum rating of 4 0 on the AATCC grey scale, on average 

Staining: ASTM standard of a minimum of 3.6 on the AATCC grey scale, on average. 


2 ASTM standard of 3.0 % change, on average. 


3 Scale* Used in Matni 

P- Poor L- Lour 

F- Fair M- Medium 

C« Good H» High 

VO- Very Good EH- Extreme^ High 



Dm: 1/9/964 47 PM 

Fife Son Comp tor EPA Conf 1 -96 Jd* 

By Fisner/Scaico 























































































12251 Tech Road, Silver Spring, Maryland 20904 (301) 622*1900 


Characteristics of Drycleaning Solvents 


Three types of solvents are used for drycleaning. 
While all are organic chemicals, their structures and 
properties are different in many respects. Chlori¬ 
nated hydrocarbon solvents are the most widely used 
drycleaning solvents in the U.S. The next most com¬ 
mon are the several classes of petroleum solvent, 
followed by fluorocarbon solvents (choionnated and 
fluonnated hydrocarbons). This bulletin compares 
the properties and characteristics of each solvent. 

Desirable Properties 

Not all organic liquids are satisfactory as dry- 
cleaning solvents. To be appropriate for use in 
drvcieaning. a solvent must possess a number of 
qualities. 

1. Its "solvent power" must be in the range that 
balances possible detrimental effects on common 
textile fibers and dyes against the solvent's ability to 
remove fats. oils, and greases. 

2. An acceptable drvcieaning solvent must be free 
of objectionable odors, and certainly must not leave 
a residual odor in garments after drying. 

3. The solvent must be noncorrosive toward the 
ordinary metals used in machine, pipe, and pump 
construction or used oniy in equipment designed for 
that particular solvent. The solvent should also not 
swell or dissolve a wide range of flexible gasket 
materials or tubing used in the construction of most 
drycleaning equipment. 

4. The solvent must be sufficiently volatile to 
allow rapid and safe drying, as well as to permit 
economical reclamation by distillation. 

5. One must be able to effectively use detergents 
in the solvent, and the detergent/solvent solution 
should be capable of carrying moisture. [The par¬ 
ticular detergent used and its concentration will 
affect the amount of moisture available for removal 
of water-soluble soil.) Many common detergents 
don't work in all solvents even though they may dis¬ 
solve in them. 


Drycleaning Solvents 


Perchioroethylene and 1,1,1’trichloroethane 

Perchloroethylene and a l.l.l.-trichloroethane are 
chlorinated hydrocarbons: they are manufactured by 
a process of adding chlonne to a base hydrocarbon. 
While all grades of each of these chemicals are the 
same basic chemical, they contain different corro¬ 
sion inhibitors, depending on their end use in various 
industries. Also, acceptable levels of impurities can 
vary from one type of use to another. Thus perc or 
1.1.1 manufactured for other industries may not be 
suitable for drycleaning use. 

Petroleum Solvent 

Petroleum solvents are obtained during the refin¬ 
ing of crude oil and fall structurally between gasoline 
and kerosene. Since these solvents are mixtures of 
hydrocarbons, they contain only hydrogen and 
carbon. 

Four types of petroleum solvents are manufac¬ 
tured. "Stoddard solvent" is the name of one of these 
types. The other three are called "140F solvent." 
"odorless solvent" and "fast dry solvent". All pe¬ 
troleum solvents are blends. The flash point of any 
petroleum solvent should never be lower than 100° 
F. However, 140F solvent has a minimum flash 
point of 140° F. 

Fluorocarbon Solvent 

Solvent F-113 belongs to a class of extremely sta¬ 
ble chemicals called fluorocarbons. Solvent F-113 
contains fluorine, chlorine, and carbon. For dry- 
cleaning use in the U.S.. F-113 (plus detergents and 
additives) has been known by DuPont's trade name 
of "Valclene." The base solvent is now available 
from other companies. F-113 is usually produced 
from perc. 


Il : l BULLETIN REPRINT—TECHNICAL OPERATING INFORMATION No. 594 










The Europeans have also experimented with 
another fluorocarbon which they call “Solvent F- 
11.“ As F-ll is a moderately aggressive solvent (it 


has about double the solvent power of F-113). it nas 
not made any inroads m the U.S. cryciear.ir.c 
industry. 


Comparison of Solvent Properties 



y*rt 

1.1.1-tnchioroetfeaee 

ftlroltan 

F-113 

Water 

boiling point 

•F 

230 

103 

300-400 

1117.8 

212 

volatility 

fCCl—1001 

2? 

91 

6 

: 280.0 


latent neat of vaporization 

(BTU/1 lb) 

90 

102 

122 

63.0 

970 

solvent power 

(K.£. Value) 

90 

124 

27-45 

i 31.0 


density 

(Ib/ftl) 

13.35 

10.97 

6.47 

| 13.16 

6.33 

tnresnold limit value 

(ppm! 

100 

330 

200 

;iooo 

i none 

suriace tension 

fdynei/cml 

32.3 

2.36 

27.6 

19.6 

•• 

flash point 

solubility of water in solvent 

(minimum temp. F) 

none 

none 

100.140 

i none 

1 

i 

i none 

I no detergent) 

*/W1 

0.01 

0.03 

0.01 

| 0.01 

> rva 

composition 


chlorinated ■ chlorinated 
hydrocaroon i hydrocaroon 

hydrocaroon 

mixture 

1 chlorinated , 

1 Huonnated I 

1 hydrocaroon i 

use in drycleanmg 


75-00* 

<1% 

20-23* 

1 1-2* 



Explanation of Terms in Table 

Petroleum solvent is a mixture, so its properties 
are variable. The numbers in the petroleum column 
should be regarded as “ball park figures." 

Volatility is a measurement of the relative evapo¬ 
ration rate of a solvent. Carbon tetrachloride— 
CC1«— is used as a reference, with a rating of 100. 
The higher the volatility, the faster a solvent will 
evaporate. In practical terms, a solvent with a high 
volatility will be removed from textiles in less time 
than a solvent with a low volatility at the same 
temperature. 

The latent heat of vaporization is the amount of 
energy, in British thermal units (BTU). required to 
convert a pound of liquid, at its boiling point, into 
vapor. The more BTU's needed, the more heat energy 
(higher temperatures or longer times) must be sup¬ 
plied to convert the liquid solvent into a vapor. 

Relative solvent power of liquids is expressed by 
the index number called Kauri-Butanol Value 
(KBV). On this scale, benzene is equal to 100 and all 
other liquids are compared to it. The higher the KBV. 
the stronger the solvent. A high KBV is usually more 
effective in removing oil and grease stains, but a 
lower KBV may be safer on some dyes, vinyls, and 
other soivent-soluble items. 


Density is expressed as an index number, known 
as specific gravity, by dividing by the density of 
water, which is 8.33 pounds per gallon. 

Threshold limit value (TLV) is measured in terms 
of the maximum allowable concentration of the sol¬ 
vent vapors in the air. The measurement is expressed 
as parts per million Ippm). The TLVs are set by a 
group of industrial hygienists and are currently use* 4 
by OSHA as its limits for 8-hour exposure. 

Surface tension is a measure of the energy that is 
holding the molecules of a liquid together in the sur¬ 
face of a liquid. The lower the surface or a fabric. 
Water, with a surface tension of 72. can be used for 
comparison purposes. Wetting is the first step in 
detergent or solvent action. 

As a solvent is heated, it releases more and more 
vapors. The flash point is the temperature at which 
these vapors will ignite if a spark is present. For 
example, the vapors from Stoddard solvent heated to 
'.00° F could be hot enough to ignite. Some liquids do 
not have flash points since their vapors do not form 
combustible mixtures with air. 

The solubility of water in solvent refers to how 
much water will dissolve in the solvent without the 
addition of detergent. Moisture above this limit will 
cause a cloudy mixture to form 


This bulletin was written by Cindi Busier. Director of Research . 








No. 4 September 199? 



From the International Fabricare Institute 


P erchloroethvlene (perc) is the most widely used drvcleanmg solvent. 

The cnemical is heavilv regulated and is likelv to be even more stnn- 
gentlv regulated in the future. In fact, in some states, the regulations are 
putting an increasing burden on drycleaners to purchase new. lower-emit¬ 
ting equipment, to report usage levels, and to tram workers. Drvcleaners 
would welcome a viable alternative to perc that would be more acceptable 
to the regulators; one that w-ould not require expensive regulatorv invest¬ 
ments. Is such an alternative available today or is such an alternative likelv 
to emerge m the future . 7 

This paper attempts to answer that important question and the answer is 
likelv to disappoint most drvcleaners and those of us who work on environ¬ 
mental issues. Although many chemicals and processes are being heralded 
as alternatives to perc drycieaning, none is reallv viable at this time. There 
are five desirable properties that all drvcleanmg solvents must have to be 
used in the drvcleanmg system. They are: 

• cleaning power. 

• no objectionable odors, 

• noncorrosive to ordmarv metals. 

• sufficiently volatile, and 
• liquid at room temperature. 

These properties are necessarv to provide the best quality cleaning and 
care for garments. Not all organic liquids are suitable as drycieaning fluids 
so these properties were sought m establishing the current drvcleanmg fluids 
in use. Manv believe that the ability of the chemical industry is vast and 
that eventually, given advanced technology, the chemical industry will 
devise a chemical that will prove to be the answer. This paper demonstrates 
that it is unhkelv that suchan alternative will ever emerge. There are several 
genenc chemical classes in which all existing and new chemicals can be 
classified. The chemical class defmes the physical properties and. thus, the 
performance ability of the chemical. It also defmes the environmental 
characteristics of any member chemical. Alternative processes are being 
proposed and investigated as replacements for perc drvcleanmg as well. One 
of these—wetcleanmg—holds some promise and. indeed, is practiced or 
should be practiced by drycleaners to some extent today. 

On balance then, the conclusion of this analysis is that no existing or 
emerging chemical and no process will replace perc drycieaning on a 
widespread scale, and perc will continue to be used by the industry m the 
years to come. The road ahead will be more difficult, however, because the 
regulations will become more burdensome and the industry will have to 
accept the fact that perc is tagged as a chemical that poses potential human 
health and environmental problems. 

Only certain chemical classes can be tapped for commercial production; 
that is, some chemicals would be extremely expensive because they are 
difficult to manufacture. Thus, the classes of chemicals that might contain 
chemicals suitable as drycieaning agents are limited and all of those classes 
are considered here. 


ALTERNATIVES 
TO PERC 



DRYCIEANING: 
ARE THEY 


VIABLE? 











Iwdartry >•€■» / S*y<**^ * 993 


Table 1 Characteristics of Generic Altemaitves 


Class 

Examples 3 

Flash 

Point 

Volatile 

voc 

Ozone 

Depletion 

Global 

Warming 

Cleaning 

Flammable 

Solvents 

Kerosene 

Petroleum Solvent 

Yes 

Yes 

Yes 

No 

No 

Good 

Combustible 

Solvents 

Terpenes, 

Dibasic Esters 

Yes 

No 

Yes 

No 

No 

Good 

Chlonntated 

Solvents 

CT, Perc 

TCE, TCA 

No 

Yes 

Some 

Some 

Some 

Good 

CFCs 

CFC'l 1, CFC-113 

No 

Yes 

No 

Yes 

Yes 

Modest 

HCFCs 

HCFC-123, 

HCFC-Mlb 

No 

Yes 

No 

Yes 

Yes 

Good 

HFCs 

HFC'43-10 

No 

Yes 

No 

No 

Yes 

Poor 

FCs 

— 

No 

Yes 

No 

No 

Yes 

None 


d see text tor full names 


RULES OF THE CAME 

Genenc chemical classes have certain characteristics. Once 
these charactenstics are known, anv chemical that falls into that 
class will have those characteristics. The balance of this section 
presents certain rules that can be applied to chemical classes. 

Some chemicals have short atmosphenc lifetimes. That is, thev 
break down readilv in the lower atmosphere. These chemicals 
form precursors that contnbute to photochemical smog. Such 
chemicals are referred to as volatile organic chemicals (VOCs). 

Other chemicals have long atmospheric lifetimes, in the range 
of five to several thousand vears. All of these chemicals contain 
the so-called halogens which include fluorine, chlorine, and 
bromine. Thev do not break down readilv m the lower atmo¬ 
sphere. Some or these chemicals—those containing chlorine or 
bromine—make their wav to the upper atmosphere where thev 
contribute to stratosphenc ozone depletion. These chemicals also 
contribute to global warming. Other chemicals—those contain¬ 
ing onlv fluorine—do not cause o:one depletion but do cause 
global warming. 

The presence of a halogen, like fluonne or chlonne. in a 
chemical suppresses its flammabilitv and most chemicals con¬ 
taining halogens do not have flash points. The presence of 
chlonne m a chemical makes it a good cleaner, the presence of 
fluonne alone in a chemical makes it a verv poor cleaner. Chem¬ 
icals containing only halogens are generally relatively nontoxic. 
Chemicals containing hvdrogen in addition to halogens are 
relatively more toxic. All organic chemicals that do not contain 
halogens are classified as VOCs. Some chemicals containing 
chlonne are classified as VOCs. 

CHARACTERISTICS OF GENERIC 
ALTERNATIVES 

Table 1 summarizes the characteristics of the genenc chemical 
classes. Examples of chemicals that fall into the first class—flam¬ 
mable solvents—are kerosene and petroleum solvent. These are 


organic solvents that do not contain chlonne or fluorine. Flam¬ 
mable solvents have flash points in the flammable range, below 
about 140*F. This is a major drawback since fire regulations 
restnct their use. Equipment must be explosion proof and storage 
requirements are stnct. Flammable solvents have high vapor 
pressures which means thev are volatile and evaporate readilv. 
This is an advantage because the garment will drv rapidlv. Flam¬ 
mable solvents are classified as VOCs and contnbute to smog 
because thev have short atmosphenc lifetimes. As a conse¬ 
quence. thev do not cause o:one depletion or global warming. 
Flammable solvents are good cleaners. 

Combustible solvents include terpenes. dibasic esters, and vanous 
other hvdrocarbon solvents. Like flammable solvents, thev are 
organic solvents that do not concain fluorine or chlonne. Thev differ 
from flammable solvents in that their flash point is higher: that is. 
they are not as flammable but thev are combustible and thev will 
bum and explode. For this reason, thev could not be used m perc 
drvcleamng equipment. Thev have low vapor pressures so thev are 
not volatile and do not evaporate readilv. Combustible solvents 
would not drv readilv and thev would require higher energy use to 
ensure drv clothing. Combustible solvents cause smog and are 
classified as VOCs. Thev do not cause ozone depletion or global 
warming and thev are good cleaners. 

Chlonnated solvents include carbon tetrachlonde (CT) and 
tnchloroethylene (TCE), both of which were once used in 
drycleamng; 1.1,1 -mchloroethane (TCA), which is used by a few 
drycleaners today; and perc. Because these chemicals contain 
chlonne. thev do not have flash points. Thev have high vapor 
pressures and so are volatile; they evaporate readily, leaving the 
clothing dry. Perc and TCE are currently classified as VOCs. but 
the EPA has proposed exempnng perc from this classification. 
CT and TCA have long atmosphenc lifetimes and, since they 
contain chlorine, they contnbute to ozone depletion and global 
warming. Production of the two chemicals will be banned on 
January 1, 1996, because they cause ozone depletion. The chlo- 












IwdMrtry >»cwi / 


1993 


Table 2 Health and Environmental Characteristics of 

Potential Chemical Substitutes 


Solvent 

PEL (ppm) 

VOC 

TAC 

Flammable 

ODP* 

GWP b 

PERC 

25(?) 

Yes 

Yes 

— 

— 

— 

CFC-113 

1.000 

No 

— 

— 

0.8 

1.4 

TCA 

350 

No 

Yes 

— 

0.1 

0.026 

Stoddard 

100 

Yes 

Yes c 

Yes 

— 

— 

HCFC-Mlb 

(400) 

No 

— 

— 

0.15 

0.087 

HCFC-123 

(10) 

No 

— 

— 

0.02 

0.017 

HCFC-225 

na d 

No 

— 

— 

0.01-0.04 

d 

na 

HFC-43-10 

(400) 

No 

— 

— 

_ 

0.25 


a ODP is Ozone Depletion Potential b GWP is Greenhouse Warming Potential 
c Contains Benzene ^ na means not available 


nnated solvents are good cleaners. 

Two CFCs—CFC-11 and CFC-113—have been used in 
drvcleaning. CFC-11 was once used in Europe and CFC-113 is 
marketed as Valdene® today. Because they contain fluorine and 
chlonne. which suppress flammabilitv. the CFCs have no flash 
points. They have high vapor pressures, are volatile, and evapo¬ 
rate readily. Because thev have long atmosphenc lifetimes, they 
are not VOCs. but they do cause ozone depletion and global 
warming. Production of the CFCs. like CT and TCA. will be 
banned on January 1. 1996. CFC-113 is a gentle, rather than an 
aggressive, cleaner. 

The hvdrochlorofluorocarbons (HCFCs) are like the CFCs 
except that thev contain hvdrogen. The hydrogen makes them 
have shorter atmospheric lifetimes. Thev still contribute to ozone 
depletion and global warming but less so than the CFCs because 
or their shorter lifetime. Production of the HCFCs will be banned 
later than CFCs. The HCFCs have no flash points because thev 
contain fluortne and chlorine. Thev are volatile and evaporate 
readilv. Because thev have relatively long atmosphenc lifetimes, 
thev are not classified as VOCs. They are good cleaners. 

The hvdrofluorocarbons (HFCs) are not yet commercially 
available but mav be in the future. They contain fluorine but not 
chlonne. HFCs have no flash points and are volatile. Because 
they contain fluorine, they have relatively long atmospheric 
lifetimes and so do not conmbute to smog. Since they contain 
no chlonne. they do not cause ozone depletion, but. because of 
their long lifetimes, they do cause global warming. The fact that 
they contain no chlonne makes them poor cleaners. They could 
not be used alone for drycleaning; they would have to be com¬ 
bined with a better cleaning agent. 

The fluorocarbons (FCs) contain fluonne and have extremely 
long atmosphenc lifetimes. They contribute substantially to 
global warming. Because they do not contain chlonne. they do 
not cause ozone depletion. They have no flash points and are 
volatile. Because of their long lifetimes, they are not classified as 
VOCs. Since they contain onlv fluonne, they are very poor 


cleaners. They do not combine well with other solvents and thev 
are probably not suitable for drvcleaning from a technical stand¬ 
point. Furthermore, they are likely to be regulated eventually 
because of their strong global warming properties. 

CHARACTERISTICS OF POTENTIAL CHEMICAL 
ALTERNATIVES TO PERC 

Table 2 presents a companson of the health and environmental 
characteristics of several chemicals with perc. These chemicals 
are either used as drycleaning agents today or they are possible 
candidates. All of them fall into the genenc categones of Table 
1. Thev include perc, which is the solvent of choice and the basis 
tor companson; CFC-113. a CFC that is used for drvcleaning 
todav; TCA, a chlonnated solvent used by a few drvcleaners 
presently; Stoddard solvent, a flammable solvent, used bv manv 
drvcleaners todav; three HCFCs which are just becoming com¬ 
mercially available; and one HFC that will not be commercially 
available for some three vears. 

The first column of Table 2 shows the permissible exposure 
level (PEL), the exposure level in the workplace set by the 
Occupational Safety and Health Administration (OSHA). In 
general, the more toxic the chemical, the lower the PEL. OSHA 
set the PEL for perc at 25 ppm some years ago but the level has 
been overturned. Even so. most users are still attetnpnng to meet 
the PEL of 25. CFC-113. a relatively nontoxic chemical, has a 
PEL of 1,000 ppm, the highest value assigned to any chemical. 
TCA has a PEL of350 ppm, and Stoddard solvent has a fairly low 
PEL of 100 ppm. The PELs for the HCFCs and HFCs have not 
been set by law; the manufacturer’s recommended levels are 
specified in the table but are placed in parentheses to indicate 
they are not legal PELs. The PEL for HCFC-123 is only 10, a very 
low value, because, in long term animal testing, the chemical 
caused benign pancreatic and testicular turnon in male rats. 

The second column of Table 2 indicates whether the chemical 
is a VOC and conmbutes to smog. Perc is currendy classified as 
a VOC but the EPA plans to exempt it from smog regulations. 









Iwdnatry >•«»» / 


1993 


The oniv orner chemical in the table ciassined as a VOC is 
petroleum solvent which falls into the eenenc class of “flammable 
solvents." CFC-113. TCA. the HCFCa. and HFCs have loneer 
atmospheric lifetimes so thev arc not considered VOCs. 

The third column m the table indicates whether the chemical 
is considered a hazardous air pollutant iHAP). Perc is regulated 
under the Clean Air Act as a HAP and. in California, as a toxic 
air contaminant. Stoddard solvent contains benzene fractions 
and benzene is considered to be toxic. TCA is classified as a HAP 
m the Clean Air Act. 

The fourth column indicates which chemicals have flash points. 
The oniv listed chemical that is flammable is Stoddard solvent. The 
other chemicals do not have flash points because they contain 
fluonne or chlonne. which suppresses flammabilitv. 

The fifth column lists the Ozone Depletion Potential (ODP) 
of the chemicals. This is a relative measure of the depletion 
potential of a substance. CFC-113 has a high ODP; TCA has a 
more modest ODP. Production of both chemicals will be banned 
worldwide on Januarv 1, 1996. for this reason. HCFC-141b has 
a verv high ODP and it is slated to be banned in the vear 2003; 
EPA will not allow its use in solvent applications where it would 
replace a chemical with a lower ODP. This means it cannot be 
substituted for perc. HCFC-123 and HCFC-225 will eventually 
be banned because of their ozone depletion, but at a later date. 
Thev would require new. tighter equipment and. since they will 
be banned, new equipment would not be a good investment. 
HFC-43-10 has no ODP since it contains no chlorine. 

The sixth column lists the Global Warming Potential (GWP) 
of the chemicals. Of the chemicals listed, oniv perc and Stoddard 
solvent have no GWP. There mav eventually be regulations on 
chemicals that cause global warming. 

Of the chemicals listed in Table 2. none is a promising substi¬ 
tute ror perc. CFC-113 and TCA will be banned soon; all three 
of the HCFCs are slated to be banned eventually. Stoddard 
solvent cannot be used widely because of fire regulations. HFC- 
43-10 is a potential alternative but it is a verv poor cleaner, it 
would have to be combined with another chemical to be techni¬ 
cally suitable and then the ocher chemical would have to be 
evaluated for its health and environmental effects. 

All spec me chemicals can be placed into the genenc categones 
or Table 1. Flammable and combustible chemicals probablv cannot 
replace perc because they arc controlled bv fire regulations. Com¬ 
bustible solvents have the added problem of not drying rcadilv. CFCs 
and HCFCs will be banned because of ozone depletion. HFCs and 
FCs arc poor cleaners and the FCs have extremely high GWPs and 
mav eventually be banned for that reason. An HFC might be 
acceptable from a health and environmental standpoint but. unless 
it was combined with a stronger solvent, it could not perform well 
technically. The stronger solvent would likely have health and/or 
environmental problems. 

OTHER PROCESSES 

Several other processes have been suggested as potential alter¬ 
natives to perc drycleaning. These would include petroleum 


solvent with nitroeen mertine. surercriticai or hauid earner, 
dioxide, and wetcieaninc 

Petroleum or Stoddard solvent can be used in eauipment tn3t 
has a nitroeen blanket. The nitroeen replaces the oxvgen which 
is needed for the perroieum to lenite or explode. The nitroeen 
acts as an "inerting" medium that prevents tire or explosion. One 
disadvantage of this option is that nitroeen inerting is expensive 
Another disadvantage is that tne petroleum solvent would still 
have to be stored and the storaee aione is often enouen to cause 
the tire marshal to forbid its use m many locations. 

At the supercritical point—verv high pressure and room tem¬ 
perature—carbon dioxide behaves like both a liquid and a gas 
and is an excellent solvent. It can oniv remove oil-based contam¬ 
inants, however, and particulates and lipstick and many other 
types of contamtnants could not be removed with the process. 
Pressure vessels are required for supercritical carbon dioxide and 
such a vessel for drvcieantng at this time mav be cost prohibitive. 
Lower pressure could be used for liquid carbon dioxide and it 
would be somewhat less expensive. A liquid process was patented 
some years ago for drycleaning. It was never commercialized, 
however, presumably because of the technical problems and the 
cost, although research is ongoing. 

Water-based methods are being heavily investigated todav. 
One water-based method under investigation employs a number 
of treatments. The most suitable treatment method is used on a 
garment by garment basis. The treatments include spotting, 
tumble drying, or laundenng. Many drvcieaners employ 
wetcleaning to some extent todav and it could be exercised more 
widely and extensively. This would allow a portion of the perc 
drvcleaning to be replaced. 

CONCLUSIONS 

All potential chemical alternatives to perc can be classified 
into generic categones. The generic categories of chemicals have 
defined properties and thev have certain environmental charac- 
tenstics. If the chemical category for a particular chemical is 
known, then the properties and environmental charactenstics ot 
the chemical arc known from the outset. All generic categones 
have disadvantages. The flammable and combustible chemicals 
pose workers danger because of possible fire and explosion: thev 
are also VOCs and the combustible solvents do not drv rcadilv. 
The CFCs and HCFCs will be banned because thev cause ozone 
depletion. The FCs cause extensive global warming and thev mav 
eventually be regulated. The HFCs are possible substitutes but 
they are poor cleaners. 

All emerging chemicals and all possible future chemicals that 
could be considered for drycleaning will fall into one of the 
genenc chemical categones discussed here. Since these catego¬ 
ries all have strong class disadvantages, it is safe to conclude that 
there is not and there is not likely to be a chemical that will 
substitute widely for perc in drycleaning. The alternative pro¬ 
cesses to perc drycleaning which include petroleum solvent 
drycleaning also have limitations; the only one that may replace 
perc drycleaning to some extent in the years to come is wetclean¬ 
ing garments that can be laundered. □ 


Written by Katy Wolf. Institute for Research and Technical Assistance. 





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W ^ W1 411,1 €•»»•< ia wKaU ar tin viUiaui ptiviMiM ai iKa N.A.D.C. I 


I 


_ NATIONAL AS SOCIATION INSTITUTE OF DYEING AND C LEANING. I NQ^ 

■■■■MHBHBEHGBHHMHl silver spring, Maryland ■■ 

'*'o* T-143 / Octooer II, 1542 

Wetcleaning Problems 


I 


In too many plant* the wetoleaning department is given littla or no thought. 
Beoause It i* an axtra operation and lnoreaaa* coat* in other department*, it 1* 
looked upon as a necessary aril. For some unknown reason, it is usually put in 
the darkest corner of the plant, and too often become* a dumping ground for inex- 
J perienced and careless employees. Actually, no other department requires a high¬ 
er skilled operator, and in no other department can as nuch damage occur through 
inexperience or carelessness. Although there are many, we will discuss seven 
primary problems of the wetoleaning department that are most often overlooked in 
many plants. 


Shrinkage i As pointed out in bulletin T-142, 
there are four factors that cause shrinkage: mois¬ 
ture, mechanical action, heat, and alkali. The more 
tnese factors are in evidence and the more in com¬ 
bination, the greater is the tendency toward shrink¬ 
age. Considering eaoh of these factors as they per¬ 
tain to the wetoleaning department, we can ascer¬ 
tain such practices as may be expected to cause 
snrinkage. 

The first f so tor —moisture --is a very neces¬ 
sary part of wetoleaning, and cannot be reduced or 
avoided. Sinoe shrinkage is caused not so nsjch by 
any one thing alone as by a combination of factors, 
it becomes increasingly important to take all pos¬ 
sible precautions to minimise the presence of the 
remaining three faotors. 

The second faotor-- meohanlcal action —is some¬ 
thing that can be at least reduced,although not en¬ 
tirely eliminated^ Wringing and aqueeiing give a 
certain degree of meohanioal aotlon. Machine wet- 
cleaning increases the possibility of shrinkage, 
because of the increased mechanical action. If a 
low water level is maintained and the machine is 
allowed to run during the draining period, the ex¬ 
cessive pounding will increase still more the 
shrinkage possibilities. The speed of the washer 
likewise is important, sinoe increased speed in¬ 
creases meehanical action. 

Tumbling wetcleaned * work still further in¬ 
creases shrinkage tendency because,here we not only 
have the factors of moisture and mechanical action 
present, but also the third factor— heat . Thus if 
there ie a potential ehrinkage problem present—that 
is if the garment has a tendenoy to shrink—we can 
expeot excessive difficulty where wetcleaned work 
is dried by tumbling. Another source of shrinkage 
due to the presence of heat is in the use of too 
hot water, or uneven ohange of temperatures of the 
rinses. Extremely cold water also will result in 
shrinkage. Even the change of temperature from a 
final warm rinse to the cold air In extraction has 


been known to oause shrinkage in oold climates. 

The fourth faotor— alkali — ia often present 
in many wetoleaning operations, either in the form 
of soap or as a builder. However, it can be kept 
at a mininum by the use of a wetting agent on those 
garments that are suspected of having shrinkage 
possibilities.- Thus the careful wetcleaner can do 
much to minimise the possibility of shrinkage on 
garments suspected of having a pronounced shrinkage 
tenaency, by endeavoring to avoid as such as possi¬ 
ble the three factors of shrinkage that can be at 
least partially controlled. 

Topping I>voa « Some manufacturers resort to the 
use oi" "topping dyes", for several reasons. Some¬ 
times a material has been dyed an off-shade through 
faulty dyeing practioe. By "topping-off" with a 
slight amount of another color, it is possible to 
correct the original mistake and bring the material 
to the desired shad*. Then again, sometimes oertain 
■naoes do not sell well, or go out of style before 
being placed on the marxet. By resorting to "top- 
dyeing" a new shade or color, in popular demand, can 
be produced. 

Material dyed with acid dyes maybe topped with 
a basic dye to get added depth and brilllano*. Or, 
on the other hand, style trends may oall for a dull 
or dusty appearance whioh can be accomplished by 
topping with another oolor to dull the brilliance 
of the original dye. Further, top-dyeing ia often 
used to produo* fanoy or unusual shades. This is 
done by first dyeing the fabrlo to an approximate 
shade of the oolor desired, and then by passing the 
fabrio through a dilute bath of another oolor, an 
overtone is brought out, resulting in an unusual or 
"different-from-average" shad*. 

This prooess might be compared somewhat to the 
practice of blueing white work in laundry praotie*. 
Aotually the blueing is a topping dye that offsets 
the yellow cast of the washed work, to produo* a 
pure whit* oolor. For example, this summer there 
have appeared on the market a large number of men 1 s 
























ten suiuur suits whlon had oaen top-ay#c with a 

dilute fugitive yellow* The trouser* of «umner 
suits often naad wetoleaning, but whan thase gar¬ 
ments wars watclaaned ih tha usual manner, tna 
yellow topping dye was removed,leaving tha trousers 
a decided gray that was entirely different from the 
coat which had not been wetcleaned. Many of these 
tat suits also were found to hare been topped with 
a dilute green to dull the brilliance of tne tan. 
After wetcleaning, a deoided reddish cast resulted 
due to the removal of this green. This same diffi¬ 
culty was enoountered in plants using a water carry¬ 
ing soap in dryoleaaing, and where the practioe is 
to separate the trousers from the coats and olean 
them with a greatly increased percentage of moisture. 
Usually suoh topping dyes are not properly set and 
are easily removed. When once removed the only 
remedy is to put the garment through a topping bath 
again. However this is not always possible due to 
tne linings and trimmings. 

Th# wetolsansr. should bs trained to recognise 
garments which have a "suspicious" look. Unusually 
brilliant fabrios, unusually dull fabrics, or un¬ 
usual colors that appear "off-shade" should always 
bs viewed with suspicion and tested before wetclean¬ 
ing. Such fabrios should be tested with the three 
reagents—10% aoetio aoid,10% ammonia, and a saline 
solution. It will be found in practically every 
case that if one of these three reagents causes a 
discharge of color on a white blotter, another one 
of the three will be found to hold or set the color. 
Then it la possible to ute this color-setting agent 
together with a synthetio wetting agent Instead of 
soap, and wetolean the garment without lose of 
color. The earns color setting agent should be used 
in the rinses as well as the suds operation. 

Color Changes i In addition to oolor change due 
to loss of topping-dye, many cases art dus to a 
ssparation of the dyestuff. This may occur in any 
blended shade, where the color was obtained by dye¬ 
ing with a combination of dyes. For example, a 
green might be obtained by the use of a yellow and 
a blue dye. If, however, the yellow was fugitive to 
alicali, the result after wetcleaning with soap and 
an alkaline builder would be the removal of the 
yellow component of the green, leaving a blue or 
bluish fabrio. The prevention of suoh damage is by 
tasting suspeoted fabrios as abovs. Ths expsrlsnosd 
wetcleaner learns to rsoognits such potential 
trouble-makers instantly* - 

Other color ohanges are often due to the use 
of dyes that change oolor in the presence of acids 
or alkalies. However, euoh ohangee oan usually be 
corrected by neutralising, unless the reagent that 
caused the color ohangs was so strong as to aotually 
damage the fabric* Reoently there have been a num¬ 
ber of cases of army officers' shirts that have 
turned color in streaks due to perspiration. Be¬ 
cause many of these shirts art labeled "dryclean 
only", some cleaners have refrained from wetclean¬ 
ing them. It Is the oontention of the Association, 
and many of the manufacturers, that the wetcleaning 
process is an integral step in drycleaning proce¬ 
dure and therefore is still within ths scops of 
such a label* Many manufacturers stats that the 
purpose of suoh a label is for the guidance of the 
purchaser so that the garment would not receive an 
ordinary washing or laundry process, but would bs 
sent to a drycleaner to prooess in ths accepted 
manner. 


The removal e' dressing one often give* tne 

appearanoe of a loss of color♦ Occasionally, tne 
manufacturer uses a dressing oil to increase lig.-.t 
reflection, whioh makes the fabric appear more 
brillant and luetroua* In oaaee of poor dyeing 
that dreasing oil alone oould not cover, dyestuffs 
are incorporated with the oil to overcome the dull 
appearance. Many of these oils are removed ir. dry- 
ciear.ing and otners in wetoleenir.g, with suosequer.t 
loss of color. Usually suer, a condition car. be 
overcome by a re-oiling process. Altnougn a solu¬ 
tion of one-naif pint of wr.ite mineral oil -to 
gallon of solvent has been the accepted method o 
re-oiling and works satisfactorily,reoently the use 
of wax-type water repellents on the dry side have 
met with increased popularity in drycleaning plants 
for re-oiling end dry siting many fabrics. 

Loss of Slting i One of tne most conanon com- 
plalnts from customers in regard to garments that 
have been wetcleaned is the failure to replace sit¬ 
ing s removed in wetoleaning, with resultant lose cf 
feel and drape to the garment. Beoause of the pre¬ 
sent demand for a fabric of good "feel" and "drape" 
rather than stiffness, the use of the new water re¬ 
pellents as siting has gained in use. (The subject 
of sitings, the different types, and methods of us¬ 
ing, was covered in bulletin T-39) 

Fugitive Dyes i As pointed out above an exper- 
ienced wetcleaner is able to recognits those colors 
thet are most likely to osuse trouble. In addition, 
he should be on tne alert to notice black-buchram or 
crinoline baoking and innerlininge, and speoial 
trimmings that might bleed and oause trouble. Be 
should then test the dye* as mentioned under topping- 
dyes. This does not mean that it ia neoessary to 
test all colors* Probably not over 5% of the gar¬ 
ments handled would fall into this "suspeoted" 
olass. After determining whioh oolors are fugitive 
and to what reagent they are fast, the wetoleaner 
can then use a synthetio wetting agent, plus the 
setting reagent, and wetolean th* garment with com¬ 
parative safety. 

Digestive Agents i Few wetcleaner* really know 
the value and application of digestive agents. Th* 
scop* of this subject covers considerable detail, 
and for this reason a separate bulletin will be de¬ 
voted to it. 

Exoes* Finishing Diffloultlee> One thought 
that should be uppermost in th* wetoleaner'e mind 
is that he should always eonsider th* finishing in¬ 
volved on any garment which pesaes through his 
hands. Often five minutes extra time spent in oare- 
ful handling in the wetcleaning department will save 
hours of time in the finishing department. In some 
plants the wetcleaned work reacnes the finishers in 
such condition that it ia diffioult to distinguish 
it from drycleaned work. Bowever in too many plants, 
such work is limp, lifeless, and badly wrinkled. 
There are seven precautions that the wetoleaner 
should observe to minimise finishing difficultiesi 

1. Extract lightly—to avoid "extractor 

breaks" 

2. Do not ovsrorowd tubs 

3. Kesp garments well opened up 

4. Avoid exoesslve squeezing, wring¬ 

ing, and twisting 

5. Procsss taffetas and satins entirsly 

on ths tabls, inoluding rinsing 

6. Drip dry—never extraot or squeeze — 

satins, taffetas, sharkskins 

7. Re-site garments which require sizing 


w 














International Fabricare Institute 

The Association of Professional Drycleaners and Launderers 


Receipts Size of Firms Subject to Federal Income Tax: 1992 

Source: 1992 U.S. Census of Business, Service Industries Subject Series 
Prepared by William E. Fisher, January 11,1998 


Tots!-* 

Operated Entirs Year —» 

Firm* 

19 765 

17 416 

Establishments 

23 313 
20.837 

Receipts 

$4 867 339 000 

Payroll 

$1 753 108 000 

•/. of Firma 

% Of 

Establishment 

With Annual Receipts of 

$100 000 000 or mors 






- 

SS0 000 000-599 999.999 

— 

— 

— 

_ 


- 1 

$5,000 000—$49 999 999 

32 

833 

$327 931 000 

$124 197.000 

0 2% 

4 0% 

$2,500 000-54 999.999 

83 

585 

$285 028 000 

$106 469 000 

0 5* 

2 8% 

$1,000 000-52 499 999 

450 

1 266 

$64 5 462.000 

$272 821 000 

2 6* 

6 1% 

$500 000-5999 999 

1.331 

1 999 

$895 125.000 

$376,057,000 

7 6% 

9 6% 

$250,000-5499 999 

3452 

3 946 

$1,174,284 000 

$436 268 000 

19 8* 

18 9% 

$100,000-5249 999 

7 784 

7.907 

$1,257,620,000 

$367 024.000 

44 7* 

37 9% 

Leu man $100 000 

4 284 

4 301 

$281 889 000 

$70,272,000 

24 6% 

20 6% 

Total 

17 416 

20 837 

$4 867.339 000 

$1,753 108 000 

100 0% 

100 0% 


Firms n Establishments 


Total-* 

Operated Entirs Year -» 

Avg. Receipts 

Avg. Payroll 

| Avg. Receipts 

Avg. Payroll 

Avg Payroll/ 
Avq Rcpts 

IVim Annual Racaipts of 
$100 000 000——or more 

. 





$50 000 000-599 999.999 

_ 

— 

— 

— 

— 

$5 000 000-549 999.999 

$10,247 844 

$3,881,156 

$393,675 

$149 096 

37 9% 

$2,500 000-54 999 999 

$3 434 072 

$1 282 759 

$487,227 

$181 998 

37 4% 

$1 000 000-52 499 999 

$1 434 360 

$606,269 

$509 844 

$215 496 

42 3% 

$500 000-5999 999 

$672,521 

$282,537 

5447 766 

$188123 

42 0% 

$250 000-5499 999 

$340,175 

$126,381 

$297 588 

$110,560 

37 2% 

$100 000-5249,999 

$161,565 

$47,151 

$159 051 

$46 418 

29 2% 

Less man $100 000 

$65,800 

$16403 

$65 540 

$16 339 

24 9% 

Total! 

$279 475 

$100 661 

$233 591 

$84 134 

— 


Distribution of Drycleaning Establishments by Their Receipt Size 


9.000 

8.000 

7.000 

6.000 ^ 

c 

5.000 E 
x 
« 

4.000 2 

5 

3.000 uj 
2.000 
1000 

0 


12251 Tech Road Silver Spring, Maryland 20904 H (301)622-1900 C FAX (301) 236-9320 



Average Receipts 





































Textile Industry Perspective 


Kay M. Villa 

American Textile Manufacturer Association 

Kay Villa is currently Assistant Director for the Product Services Division of the 
American Textile Manufacturer's Institute. She is the author of numerous publications 
related to textile standards, and is on the Board of Directors of ASTM. 


Good morning. 

This morning I would like to cover a couple of issues. First of all, I would like to tell you more 
about ATMI. I also have a few comments about the Care Labeling Rule. Then I want to talk very briefly 
about alternative cleaning technologies and their relationship as I see it—or as ATMI sees it—to the Care 
Labeling Rule. 

To qualify for membership in our organization, a company must be involved in manufacturing of 
textiles. That can include creating or spinning a yam, taking it and weaving it into a fabric,—or for that 
matter, printing or finishing. Thus, a company must be involved in some aspect of actually creating a 
textile product. 

Our members typically make fabncs, but they also make literally thousands of different products. 
They make anything from yams to thread to geotextiles and filtration systems. But we have a large 
number of members, in fact, that make end products. We also have a few rare companies that actually do 
the textile manufacturing and also make an apparel item. We do not represent apparel interests, however, 
some members are manufacturers that are involved in the manufacturing of home furnishing products, 
such as floor coverings, mgs, carpets, sheets, pillow cases, and towels. 

To give you some idea of the scale of our industry, we currently represent about 75 percent of all 
fiber consumption used in textile mill operations in the United States Our sales were 60 billion in 1995. 
Our shipments were $70 billion and we currently are modernizing at about $2 billion annually. And that 
is a very large number. But when you start looking at the capital expenditures that go into textile 
manufacturing, that number diminishes very quickly. A typical loom runs anywhere from a hundred 
thousand to a quarter of a million dollars. 

In order to put in a finishing line if we wanted to modify some aspect of the production, the cost 
ranges from half a million dollars to $6 million, depending on the operations. In relative scale to the 
world in terms of world fiber consumption, the U.S. textile industry produces only about 5 percent of all 
manufactured wool fibers. It represents less than 1 percent, probably around half a percent, of all silk that 
is utilized. 

For the overall synthetics picture, about 25 percent of all broad-based synthetics are utilized in 
U.S. textile mill operations. Remember, though, that this figure includes polyester, nylon, polyolefin, and 
a number of other fibers. I know that many of you are interested in rayon and acetate. Right now, the 
data doesn't break it down specifically. This is purely a guess— but I would guess that U.S. rayon and 
acetate production is probably somewhere within the 10 percent range of world production. 


112 


You have seen several versions of this diagram over the last couple of days, but let us see where 
we fit into the whole broad picture. If you look at the green boxes near the top of the pipeline, this is 
essentially where ATMI members fall. 

ATMI has two programs that we would like to describe to you. Our industry, in fact, is currently 
using pollution prevention programs. We have a program called E3, Encouraging Environmental 
Excellence. I have literature on it. If you would like more of this literature, please give me your business 
card afterwards. 

This program is voluntary and more than half of our members are enrolled in it. Member 
companies are required to develop a management system program for their environmental policies and 
must exceed EPA local, Federal, and state regulations. In essence, what happens is that the company 
meets ISO-14,000. I am not going to say they absolutely meet that standard, but it is a parallel program to 
the ISO-14,001. If the company brings in an outside third party certifier, they, in fact, would qualify for 
ISO-14,000. 

We also have a parallel system for worker safety and health called Quest for the Best in Textiles. 
It is a similar type of management program. However, in this case, it is an eight-point program. 

The Care Labeling Rule was promulgated in 1971 and requires disclosure of various types of 
information on the product label. For apparel and retail roll goods, for example, when you go to a retail 
store and buy a bolt of fabric, information must be provided to the consumer at the point of sale on how to 
care for that product. Many of you may not be aware of this requirement. Hie industry has been doing 
this voluntarily since 1971. There is no mandatory requirement for labeling of home furnishings. 

There are no specific requirements for industrial products. There are no requirements to tell you 
how to take care of your tents or your gym bags, but textile manufacturers are required by law to provide 
information to our downstream customers about the care of that product. If I were a manufacturer 
providing a raw good, and selling it downstream to someone in the apparel sector, I would be required on 
the disclosure of the sale (with the invoice) to provide information to my downstream customer on the 
care of that product. 

ATMI supports the use of the Care Labeling Rule. We think it is beneficial to both consumers 
and manufacturers and retailers. It provides manufacturers with a product that has a longer overall life 
and it protects their investment in that product. For manufacturers and retailers, it is important to us 
because we know if consumers are, in fact, pleased with that product and the care of that product, they 
will be a repeat customer. The Rule also gives us more freedom with our resources because we do not 
have to address specific questions from consumers saying they purchased something but don't know how 
to care for it. 

We were pleased in January of 1997 to see the FTC amend the Rule to allow the use of symbols. 
This is extremely important in our global marketplace and we all know that textiles are a global product. 

It is very easy to take a product and move it— a commodity, roll goods, or an apparel item or home 
furnishing item—from one country to another. 

The use of the symbols helps us do this. Regarding alternative planning technologies, there are a 
couple of forerunners that are out right now and I know there are a number of others that are emerging 


113 



into the marketplace right now. The primary ones that we have been talking about or focusing on over the 
last three conferences have been on the eco or wetcleaning techniques. They are entering into the 
commercial marketplace. 

Carbon dioxide and ultrasonics at this point are really still in the exploratory stages. One thing 
that we as a textile industry really need from all of you is data. We need to know what fabrics work. We 
need to know what fabrics aren't working. We need to know the problems you are having with fabrics or 
apparel items, so that we can try to address those issues of integrating our products into these new 
cleaning technologies. 

But this also requires all of us to provide both qualitative and quantitative analyses, tools and 
standards, and methods in order to do this. It is one thing to say it shrunk. Well, how much did it shrink? 
Did you use a standardized procedure? That is the only way that we as manufacturers can qualify our 
products as we go about developing them. 

We believe that the new technologies should be integrated into the Rule, but I also would 
stipulate that it really depends on commercial availability. We do not support a mandatory requirement to 
list all types of care instructions on labels. Let me give you an example. To make us go about our job of 
testing the Rule against 15 different technologies becomes cost prohibitive. Those costs are going to be 
passed on to the consumers and in a price competitive marketplace, that makes it extremely difficult for 
us. 


Let me give you another example. I brought a few props with me. This is a wash cloth. Now, 
this is a voluntarily labeled product. This is a pre-NAFTA product given to me by my mother about 15 
years ago. It has one very, very small label and the care instructions on this label are only about three 
quarters of an inch by three eighths of an inch. 

I recently purchased a new set of towels and the label is now about two inches by one inch. The 
reason why the label size went up—the care instructions are basically exactly the same—was that, for this 
company to market its product through NAFTA, it is now required to put the instructions in English, 
Spanish, and French. We have gone up about four times the size in order to provide this information to 
the consumer. 

If you require us to test this product against all types of cleaning technologies, we would then 
have to dryclean this product which, in my opinion, only increases the use of perc. I don't think that is the 
goal of this group. Then suppose we move to 15 different types of care symbols or care techniques, and I 
want to market that product internationally and I need to have it in 12 languages, I could end up with a 
label that is almost as large as the product. 

We know for a fact that consumers hate these large labels. We hear it constantly from them. 

They ask us to please make them smaller, please make them more concise. This has even become a 
safety issue. We had a member who was sued because a consumer had scratched an eye on a product 
label. Therefore, it is imperative for us to try to keep those labels as small as possible and we would 
certainly appreciate any assistance that you can give to us in that regard. 

Finally, we have one other concern about the potential licensing or trademarking of particular 
types of processes with regard to symbols. That is, if I want to convey the information to the consumer 
on the product label, we prefer not to see a licensing agreement or a trademark being earned on that 


114 


symbol. I have worked very diligently over the last five years with everyone at this table, on care labeling 
issues related to our recent NAFTA agreement. One of the biggest stumbling blocks for us has been the 
international care symbol system because there is no licensing or an intellectual market held on that 
system and it actually forced the United States to go to another care labeling symbol system. 

We would very much like to integrate all of this at an international level, not just here 
domestically within the United States. 

I thank you for your attention. 


115 



Consumer Perspective 


Nancy L. Cassill, Ph.D. 

UNC School of Human Environmental Studies 

Dr. Nancy Cassill serves as President of the International Textile and Apparel 
Association and is a member of the American Collegiate Retailing Association and the 
Fashion Group. She is Associate Professor of Textile Products Marketing in the 
Department of Textile Products Design and Marketing at the University of North 
Carolina at Greensboro (UNCG). 


Thank you for the opportunity to participate in today's panel on care labeling. Two session goals 
for this 15-minute presentation relate first of all to sharing with you some insights regarding today's 
consumers, including care labeling. 

The second goal is to propose some action plans to move consumer awareness and understanding 
forward. To address the first goal, I would like to begin by sharing some consumer insights with an 
environmental scan of today's consumers and then narrow the focus to include consumers and care 
labeling. 

IWIN is an acronym meaning "I want it now" that is used by Kurt Salmon Associates, KSA, 
known to some of you, to com today's consumer. "I want it now" refers to consumers wanting products, 
services, and satisfaction with textile and apparel products and services. Consumers are demanding. 
Consumers are vocal and the winners—the fiber producers, the mills, the manufacturers, contractors, 
retailers and fabricare specialists—are companies with the strongest consumer loyalty. That means they 
are meeting consumer demand now. 

Today's consumers know for the most part what they want and they are tough critics in the 
marketplace. For example, a recent study completed at UNCG found that in working with a department 
store in apparel sportswear, the most loyal consumers were also those who were the most dissatisfied. 

We reached the conclusion, at least with this sample, in working with this department store unit, that 
familiarity can breed contempt. 

Apparel consumers are making savvy purchases and are value driven spenders. Some consumers 
are practical thinkers, going through a very detailed thought process. For example, for some consumers, 
"dryclean only" requires a considerable thought process pnor to purchasing a product. 

Today's consumers are also seeking value for the dollar, and value and value-added strategies are 
two concepts that have been discussed in various sessions at this conference. Consumers are also 
selecting apparel products that fit various lifestyle choices. Thus, we have seen an increase in the 
marketplace in outdoor apparel products and many have innovative performance fabrics. 

Consumers are time starved, with some consumers shopping less than, believe it or not, one hour 
per month. In contrast, some teenagers are shopping in excess of 12 hours per month and they have the 
discretionary income to both shop and purchase during those 12 plus hours. 


116 


Let's narrow the focus on consumers and look at consumer apparel preferences. Today's 
consumers are seeking, in general, comfort over couture and they have apparel preferences for versatile, 
comfortable and affordable apparel. There has been the continuation of the casual workplace and the 
introduction in the last 18 months of what is known as the third wardrobe. This third wardrobe is 
something that has occurred since I reported at the EPA conference in 1996. A third wardrobe is a 
wardrobe that facilitates transition from the office or the business environment to the social environment. 

What is encouraging to the fabncare specialists is that a high percentage of this third wardrobe is 
dryclean only and offers some drycleaning and wetcleaning opportunities for the fabncare specialist. 
There has also been continued growth in terms of performance fibers and fabncs. 

Now, my home town is Greensboro, North Carolina, and I am proud to say that we have a 
significant amount of fiber and fabnc and manufacturing innovation occumng in Greensboro. Many of 
these companies that have made significant investments, not only in capital but also in human resources, 
are really leading the way in the global marketplace with fibers, fabncs, finishes and end use 
manufactunng. Many of these innovations are going to produce some interesting challenges and 
opportunities for the fabricare industry. 

Value is also a word that is heard frequently. Research conducted at UNCG has found an 
interesting apparel value equation. The numerator and denominator are no longer price value 
relationships with apparel products for consumers. In the numerator, you have issues that are not only 
product attributes, but marketing issues, and then the social psychological aspects in terms of risk and 
self-confidence factors. In the denominator, for the consumer's value equation, are the cost factors. But 
this is not just the cost of the product; consumers are factoring in the continual cost of the care processes 
that must be required for the product. 

The term "value" is still both overused and underused, especially as it relates to consumer's care. 
Let's look at care labeling as it relates to consumers because care labeling and consumers' understanding 
of it remain a very challenging research area. Today's consumers are educated and are, for the most part, 
label conscious. For these consumers, care is an important criterion as they enter the marketplace to 
evaluate apparel products. 

However, for these consumers, care may not be the most important criterion; it may come into 
consideration but the final decision in terms of purchasing a product may not be primarily for the care 
requirement. Brands are still strong in the marketplace and, since 1996, we have seen a growth in what 
we would call the non-traditional brands. We have seen real excitement but also growth in the private 
label programs at department stores. I think Arizona brand is a classic example of those, as well as the 
private labels of some of the specialty stores, such as the Gap and in the Limited's array of their products. 

These brands are strong, have grown over time, and continue to have the implications of being 
even stronger. Thus, it is extremely important that the private label retail representatives be brought into 
your discussions because they are making decisions related to care issues. 

Other issues about labeling relate to country of origin and fiber content. You are aware that as of 
July 1st, 1997, care symbols can be used with care requirements on care labels. You have already heard 
some issues expressed by other panel members related to additional cost, as well as consumers' frustration 
with adding both more labels and larger labels. 


117 


A recent focus group at UNC Greensboro found that consumers did notice care symbols, but were 
not knowledgeable about what they represented in terms of care requirements. As a result, a challenge 
exists for alternative cleaning methods, such as wetcleanmg when, in fact, there is little known from the 
consumer's point of view about existing care requirements, such as drycleaning and hand wash only or 
hand wash. Consumers are distrustful in part with low labeling, and some just do not trust any labeling at 
all. 


Let's take care a step further and look at some of the fabncare services. "Just Do It" is a slogan 
that is used by Nike, but it is also used by consumers seeking professional fabncare services. When 
consumers fear care labels, they are not educated about the differences between drycleanmg and 
professional laundry services. Nor are they educated about the differences between wetcleaning and 
professional laundry and home laundry. I reported this information in 1996 at the EPA conference, and 
there has been little change in consumers' understanding of fabncare services, except for the bnef pilot 
studies that have been shared at this conference. 

Another care labeling issue relates to care responsibilities. The female is the predominant fabnc 
caregiver. She is also making 70 plus percent of all apparel product purchases in the marketplace. With 
new technology and new and improved agents and developments, there are more opportunities for home 
laundry for today's products. 

Earlier I mentioned performance fabnc innovation. We are seeing more and more performance 
fabncs in the marketplace; and many of these lend themselves to home laundry. However, opportunities 
do exist for the approximately 55 to 65 percent of the population that use some degree of professional 
fabncare services. 

Remember that today's consumers have time compression, the need for a professional 
appearance, are again purchasing business apparel that supplements their casual business wardrobe, and 
are open to product newness. We have seen product sameness in the marketplace for several years and 
now we are seeing some product innovation in the textile and apparel area. Consequently, there are still 
opportunities for this. 

Where do consumers learn about care requirements? From two sources. One is personal sources 
and experience. The second relates to nonpersonal sources. Personal sources include history, such as 
personal or parental or family influence, and consultation with personnel and the retailer, the work 
environment. Non-personal sources include some care information, including the hang tags and the care 
labels. 


Where do consumers get help with care questions? Again, from personal sources, the fabncare 
professional, friends, family, work and sales associates, and non-personal pnnt sources. Personal and 
nonpersonal approaches should be used in implementing educational strategies that are discussed in your 
work groups. 

Manfred Wentz has proposed a textile spectrum and I want to propose a consumer spectrum for 
addressing consumer care label issues. A mass market approach to this important issue—meaning that 
you would be trying to address issues and concerns of all consumers—would be both an ambitious and a 
very frustrating experience. 


118 


Research at UNCG has found that there are three demographics that provide one way to segment 
consumers regarding care issues: age, income and employment. Those of you in the audience with some 
consumer research in your background recognize that using demographics as a segmentation tool will 
give you a prediction power of only about 10 percent, predicting about 10 percent of what consumers will 
purchase. 

Therefore, you can add another marketing tool called psychographics. These are the lifestyle 
issues related to how consumers spend their time and their money. That bolsters your predictability, 
perhaps up to 20 or 30 percent, depending upon the variables in your consumer sample. In this 
example—and this is one of many that can be discussed in the workgroups as well as the general session, 
we have taken just a psychographic in terms of taking employment a step further and learned from those 
employed consumers their orientation to employment. 

Is it a professional orientation in terms of a career or is it considered more than just a job? I 
would propose, and past research has found, there are some real market opportunities for the fabncare 
industry, especially with alternative cleaning methods for the professional or career segment. This 
happens to be a segment that, both in history and today, is outsourcing the business apparel and the 
business casual with the fabncare specialists. 

Ed Barlow's presentation on Tuesday morning challenged conference participants to understand 
and take action regarding six 21st Century success dynamics. Two of these dynamics, real time 
responsiveness and obsession with customer satisfaction, merit attention in researching today and 
tomorrow's fabncare consumer. 

I would like to bnefly propose five action plans for consideration and discussion. The first one is 
get to know your consumer. How do you do that? Ask the consumer. A large consumer study needs to 
be undertaken to find out the issues, the answers, and the level of education of consumers in the 
marketplace. 

Who is and who should be buying care services? In addition to asking the consumer, explore data 
mining opportunities. Well, your question is how do you data mine, perhaps, or where can we get data 
that assist us? Some of the representatives here at the conference have already offered to share some of 
the data that they have in-house or from their studies. 

Go to your fabncare specialists in your plants for data that they have collected. Don't forget 
about your partners in retail, who are very efficiently mining their databases, predominantly their credit 
card data in terms of product purchases, as well as expenditures. And you can tie that back to SKUs in 
terms of style types and care requirements. Don't forget about your apparel producers. Who are also data 
mining. They have access because of category management programs that they have with retailers and 
have a significant amount of data. Mills are also becoming more vertical and have great information. 
While it may be more qualitative information, that would be helpful to you as well. 

What is driving the decision? We must answer this question. That seems to be a question that 
perhaps is a source of unknown information and may be a source of frustration. 


119 


What attitudes do consumers have about environmental actions with apparel products? Do we 
know the answer to that question? How do these attitudes translate and when do they translate into 
behaviors, such as purchasing behavior and care behaviors? 

You must know consumer awareness before you know the proper way to educate the consumers. 
After completing action plan 1,1 would propose action plan 2, to find ways to creatively create consumer 
pull through. Wetcleaning pilot data has been shared at this conference. Collect and use consumer 
research to establish and implement strategic plans to market wetcleaning to consumers. 

The third action plan is to invest in building and maintaining customer loyalty. We all know the 
adage that maintaining a current customer is more cost effective than recruiting a new customer. 
Completion, I propose, of action plans 1 and 2, can lead to customer loyalty strategies. This then can be 
factored into the system in the various workgroups to build consumer-focused processes and to give the 
group insights in terms of marketing, especially alternate care services. And then, finally, structure the 
plan around consumers' needs, preferences, and behaviors. 

Thank you. 


120 


Consumer Perspectives: Care 
Labeling 



Nancy L. Cassill, Ph.D. 

Textile Products Design and 
Marketing 

University of North Carolina at 
Owensboro 


|S “Age of the Consumer” (KSA, 
“ 1998 ) 



■ I WIN (“l_WANT_|T NOW”) 

■ Demand dictates supply 

■ WINNERS: Companies with strongest 
consumer loyalty 



Consumer Perspectives: Care Labeling 


1 















Insight: Today’s Consumer 





- Know what they want 
-Tough Critics 

- Savvy Purchases 
-Value Driven Spenders 

- Practical Thinkers 





3 / 20/98 


Insight:Today’s Consumer 
(continued) 


- Greater Demand for their Dollar 

g *xc. 

- Apparel vs. Lifestyle Choices 

- “Time Starved” 



Consumer Perspectives: Care Labeling 














Insight: Apparel Preferences 

■ Comfort over couture 

- Versatile 
-Affordable 

- Comfortable 

■ Continuation of Casual Workplace 

■ Growth of Performance Fabrics 

■ Value: Care is part of cost 


3 / 20/98 



Insight: Care Labeling 




.y** *v. 





■ Educated consumers who are label 
conscious 

- Care is important criteria 

- Care labels are important 

- Brands are still strong 

• “Non-traditional” brands even stronger 

- Country of origin 

- Fiber Content 

3 / 20/98 


Consumer Perspectives: Care Labeling 












v~r- 


m 




'esse 



Insight: Care Labeling 
(continued) 

■ Notice care symbols but do not 
understand 

■ Distrust with “low labeling” 

■ Distrust with all labeling 


3 / 20/98 



Insight: Fabricare Services 


■ Not educated about difference between 
dry cleaning and professional laundry 
services 



■ Not educated about difference between 
wet cleaning and professional 
laundry/home laundry 


-- 


3 / 20/98 


Consumer Perspectives: Care Labeling 























pi Insight: Care Responsibilities 






■ More possibilities for home laundry 
(today’s fabrics) 

■ Reality-PROFESSIONAL 
OPPORTUNITIES!!! 




- Time Compression 

- Professional Appearance 

- Resurgence in Business Apparel 

- Blends/Product Innovation 

3 / 20/98 


Insight: Where Learn About 
Care 



■ History (“Parental Influence”) 

■ Trial and Error 

■ Care Label 

■ Consultation (Retail Sales, Friends, 
Associates) 




3 / 20/98 


Consumer Perspectives: Care Labeling 


5 
















Insight: Help with Questions 




■ Print 


„ - Care Label 

- Detergent Package 

■ Personal 



- Fabricare Professional 

- Associates 



3 / 20/98 



Insight: Care Consumer 
Segmentation (CCS) 

■ Age 

■ Income 

■ Employment 




Consumer Perspectives: Care Labeling 



















I I 


Insight: Employment 
Segmentation 


■a»' 

\ ’? *.7 

•scan 

Professional 

vs. Service 

a? 

“Career” 

“Just-a-Job” 


‘Outsourcing for 

‘Home Laundry 


Business Apparel 



Business Casual 



3 / 20/98 



Insight: Action Plans 

#1 Get to Know Your Consumer 

- Who is/should be buying care sen/ices? 

- What is driving the decision? 

- How can you reach? 


i.-.r«r 


3 / 20/98 



Consumer Perspectives: Care Labeling 


7 
















Insight: Action Plans 



#2 Find Ways to Create Consumer Pull- 
through 

- Use insights to predict care needs 






3 / 20/98 



be Insight: Action Plans 



#3 Invest in Building and Maintaining 
Consumer Loyalty 

- Satisfy current consumers before attracting 
new consumers 



Vr+rKt- 


3 / 20/98 


Consumer Perspectives: Care Labeling 





















*A«* 

13 } 


Insight: Action Plans 



#4 Build Consumer-Focused Processes 
- Use Insights in marketing (care services) 




m Insight: Action Plans 


#5 Structure Plan around Consumers’ 
Needs, Preferences, User-behavior 



- 


3 / 20/98 



Consumer Perspectives: Care Labeling 


9 
















Report from Apparel-Retail-Consumer Discussion Group 


Barbara Warren, Chair 


Well, the first bit of news is that the Apparel-Retail-Consumer Discussion Group met and 
we are now a workgroup, I guess, and we also, interestingly, had some discussion and decided after the 
whole session to stay together. So, I think that is an interesting development. 

At first, we thought that it might be more appropriate that the consumer be split off from 
apparel and retail. But we had enough issues in common to feel that it might be useful for us to stay 
together, at least at this point. 

So, we have two co-chairs, Margit Machacek, and me, Barbara Warren. I hope I am 
saying it right. We found it very useful to list issues that were consumer issues, retail issues, and apparel 
issues. We brought up things that have been brought up before in some of the other workgroups, such as 
the labeling issue, proper garment care, quality of the services, education at all levels testing, test methods 
in terms of industrial ecology, and the design and construction of the garments and the importance of 
design and construction. 

We even got into the education of the buyers; independent testing labs. One common 
issue was the information pipeline. I think the information pipeline is a very interesting issue. 

Finally, we talked about—you have to remember this is our first time together—about 
getting additional parties involved. I think each person who was with a consumer organization, either 
retail or apparel, is sort of charged with trying to think about who else needs to be involved in this 
process. 

At our next meeting, hopefully, we will identify some goals for our work group. 


121 


Report from Outreach and Education Workgroup 


Sylvia Ewing-Hoover, Chair 


The Education and Outreach Committee had, I think, a very productive meeting and we have a 
couple of date lines for people who are participating that you may want to share in the general body. By 
the 10th of April we wanted to start collecting education and outreach-related materials that you may have 
m-house. We found that people here didn't know about some of the resources that exist. So, in keeping 
with our goal, our first goal of being a clearinghouse for information, if you have materials that you think 
we should have, please send them to CNT by April 10th, to the attention of Anthony Star. 

On the 17th of April, in keeping with another one of our goals, please send to Sid Leiken of 
Prestige Cleaners any material related to certification. We know that this goes across the workgroups, but 
we wanted to, again, start to be a clearinghouse for information on how states have handled outreach and 
education. Steve Risotto and other people are going to share information from Canada and other places. 

Our mam strategy and first goal is to educate cleaners and to help them educate their customers. 
We know that we will probably be working with a consumer group, but our main focus is not yet the 
broader population, but rather people who are customers or whom the cleaners hope will be customers of 
their shops. To that end, we want to put together generic marketing material and work on a definition of 
wetcleaning. This is not technical information for the technical people, but rather information to help 
cleaners explain how what they do is different from laundry and to help their customers understand why it 
is done in a professional setting. 

So, again, we will be working in synergy with people who are probably developing that kind of 
definition for a more technical purpose in the long run, but our main focus is marketing and consumer 
education and customer education purposes. 

Participants strongly expressed the need for two things. One was a matrix, but a quick and 
accessible one. Some of the other committees will be working on this also. We wanted to make sure that 
we could at least have a collection of some alternative packages of materials so that cleaners soon would 
be able to get the last IFI matrix and whatever other matrices are available, as well as the latest 
information on the pros and cons of wetcleaning and other alternatives. So, that is something that we 
wanted to see happen quickly and we have a committee working on that. We haven't set a deadline, but 
we will because I know Mary Ellen wants one. 

Overall, the focus of our committee, again, is to make cleaners successful by having information 
to help them do their job better, explain it better, and keep customers coming in. And that is the first step 
of our committee. 

Thank you. 


122 


Report from Textile Workgroup 


Kay Villa, Chair 


I represent the Textile Working Group. I would like to show you the goals. We had 11 
participants in our working group and we devised these goals. We modified our original goals and, in 
fact, made a couple of other modifications, additions, and editorial changes. 

But this gives you a rank order of what we really foresee as where we are going and what we 
want to do. As a first goal, we definitely need a definition for alternative cleaning practices and 
wetcleaning. That is imperative to the textile and apparel sectors. If we don't know what we are talking 
about, we don't know how to begin to change and modify the product so that these items or our fabrics or 
components, in fact, can be cleaned through these new technologies. 

The second goal was to develop test methods and accompanying definitions, so that we can do 
the assessment. 

Then the third goal was to identify issues related to care labeling practices in general. 

The fourth goal was to create and implement methods of communications throughout the entire 
pipeline, from the fiber side of the business, all the way down through the consumer to the fabncare 
representatives. 

Alternative Cleaning Procedures (ACPs) should be developed in an environmentally friendly and 
cost effective manner. Economics is really what is going to drive this. So, we want to make it viable for 
all parties and for consumers to make sure that these new technologies, in fact, can coincide with business 
practices. We felt it was important that retailers are really a central stakeholder in all of this because as a 
textile representative, it doesn't matter what someone wants me to do. It is really what the customer is 
going to buy. The ultimate group that makes the decisions on what is sold is the retailer. So, it is 
imperative, in fact, that retailers be informed about these new practices and can begin to take some steps 
to implement or make decisions on products. 

That, in turn, forces us, as textile manufacturers, to try to be working along this pipestream to 
make sure that all of the products that we are putting out there are compatible. You can't make a leap of 
faith from fabncare all the way up to the textile sector; everyone else in between must be involved. But 
the retailers are a key player in all of this. 

The last goal involves ways to incorporate environmental life cycle considerations into academic 
programs, academic programs for textile manufactunng, apparel and retail. If we want to see this 
continuum all along the pipeline, our new people coming through our new replacements into our jobs and 
into careers in the field, in fact, must be aware of these considerations. 

So, these are the goals. A specific work item that we have identified to be worked on 
immediately is a recommendation that a definition of wetcleaning be developed by the American 
Association of Textile Chemists and Colorists in their Research Committee RA43. 


123 


They will be meeting during the last week of May in Baltimore, Maryland. If you want more 
information on the meeting, their phone number is 919-549-8141. We really would like to see companies 
with new technologies or operating wetcleanmg operations to attend those meetings so you can begin to 
convey information to us and we can develop those test methods. 

The second thing we talked about was more specific, developing different types of test methods, 
not only for a component, but also for the end article. It is not just a matter of testing the shrinkage of a 
fabric, but also the shrinkage of an entire garment. What we are talking about is long-term performance 
standards for end items. That is a long-term commitment but that work will be ongoing. 

We recommend that AATCC hold a forum in the near future to bring together the companies or 
parties involved in these new alternative cleaning processes to meet with the technical people who are 
involved in developing test methods and standards. In many ways, if you do that, you will reach 
members of the apparel and retail and textile communities. 

We also recommend development of a database of problems. For instance, one item that was 
suggested is that a survey could be developed to be handed out to new alternative cleaning processing 
organizations or companies. Where you are having problems, fill out a form and explain the problem. 

As a textile manufacturer, if you tell me rayon is a problem, I will say, well, okay, rayon is a 
problem. If you tell me a rayon crepe with a turquoise dye is the problem, then it becomes much more 
tangible for me to identify specific types of processes that, in fact, may have to be modified. 

Our fifth recommendation is to try to get more retail organizations and retailers and importers 
involved in all of this. The last recommendation was to try to establish some linkage between fabricare 
interests and the sundries manufacturers and that is one key stakeholder we think is really missing —that 
is, the interface in spots and zippers. Those types of companies, in fact, that produce those products are 
not involved in this process also need to be involved. 

And that ends my report. 


124 


Report from Science and Technology Workgroup 


Manfred Wentz, Chair 


I am reporting on the Science and Technology Workgroup. 

There were 24 participants at the workgroup meeting. We began by reviewing the document 
from the January conference and spent a great deal of time discussing real world studies in comparison 
with laboratory studies. We recognize that there is a need for both of them and that laboratory studies 
would be used to establish a baseline, but, that whatever that baseline is, it needs to be put into the real 
world in order to be evaluated. 

So, we redefined the goals of the committee. There were five goals identified at the January 
meeting and we decided that the most important and the predominant goal of the committee was to 
develop an objective way of assessing emerging technologies. The group decided to start with the IFI 
matrix, look at the criteria and the technologies to be evaluated, and try to find both criteria and 
technologies. 

We vowed to have this done. Each person in the workgroup would have this done and submit it 
to EPA by a June/July time frame and then Cindy Stroup would compile that and pass that around to all 
of us in the workgroup and we would refine it. This way we can all be on the same page talking about the 
same thing when we are talking about technology assessment. 

The second goal we identified was to develop an outreach program. We thought that it would 
best be handled by another committee but that our committee would generate the science or the 
technology that it was based upon, so that it is based upon sound science. Thus, we would be responsible 
for developing that. 

The third goal was to change care labels, to recognize alternative cleaning technologies and each 
individual committee member will respond to FTC because, obviously, they are the ones who will change 
the care labeling requirements. But we have an obligation to respond to the FTC and to give them our 
input. 


The fourth goal was to develop a standard definition of wetcleaning and each member made a 
commitment to respond to the FTC on the definition of wetcleaning and to give input, so that one 
standardized definition can be developed. 

Goal five, finally, is to maintain regulatory stability, which seemed like a good idea to all of us in 
the committee. However, we realized that this is out of our domain, so we removed that as one of the 
goals of the committee. 

Essentially, that is what we accomplished. 


125 


Report from Dry Cleaners Workgroup 


Bill Seitz, Chair 


Before I get into my remarks or the committee remarks, I would just like to at least speak for 
myself and say that I thought that the time that we have spent here was veiy, very well spent. 

I would like to thank Mary Ellen Weber for the fine job she did in stepping in for Cindy Stroup, 
who unfortunately couldn't be with us. And I personally think you did an excellent job. 

I would like to thank Cindy Stroup for all the work that she did in preparation, and the excellent 
job of EPA staff and the staff of Westat, who did an excellent job and I think we want to thank them. 

And from an industry perspective, I don't know how many of you know how these things get 
together, but there was a key person from industry, who helped coordinate this program and I would like 
to thank Manfred Wentz for the excellent job that he did behind the scenes in helping make this the great 
success that it has been. 

There was some frustration with the group that I was involved in and it just wasn't with me. I 
have to quote my good friend Manfred's comments yesterday that frustration isn't bad if you can turn it 
into a positive action. That is what we tried to do. 

Probably the most important part of what was discussed was the need to reach the people who we 
have all been talking about, but unfortunately didn't show up in large numbers and that is the drycleaner. 
The reasons are obvious. It was a weekday. It was very expensive. These fellows and gals are working. 

But unless we find a way of communicating all the things that we accomplished or hoped to 
accomplish with the grassroots, then we will have not wasted our time, but will not have taken advantage 
of our time as well as we could. 

So, for the short term, the primary objective is to reach the grassroots. How do we get out the 
message? The message has got to be more than just the printed pamphlet, a brochure. It has got to be 
some way of communicating with these people on an eyeball to eyeball, one to one, or a group basis. 
Some of the suggestions were to work more closely with the allied trades in getting that message across 
the possibility of holding area meetings so that we can talk to the people who are most affected by the 
actions that we are taking. 

Other issues include the concerns of the drycleaner, the uncertainty of what he or she has to do 
about the future, and dealing with the reality of problems that exist, the environmental problems, the 
remediation problem, the legislation that is pending—HR1711—and how government feels about that and 
whether it is prepared to support that action. 

We also need to find a way of keeping the momentum and the synergy of working with all of the 
other groups that are sitting at this table; developing a matrix, the objective evaluation of alternative 
technology, the equipment and the effectiveness of the equipment; financial assistance to small business 
in being able to afford the equipment we also need a technical evaluation of the equipment, that is, the 
feasibility, depending upon size, economics, the nature of the business, the health and environmental 


126 


considerations of making these new changes work, and certainly the importance of care labeling and the 
clarity and practicality of what comes out in terms of guidance for the industry. 

That was kind of short term, mid term; long term—a certification program, a certification of 
equipment, a certification of operators and a certification of the facilities. If we can do that all by the end 
of next week, we will have accomplished our objective. 

Thank you. 


127 


APPENDIX - LIST OF CONFERENCE ATTENDEES 


128 



EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Adamson, Ken C. 

General Manager 

Langley Parisian Fabricare Services 

12 Walnut Street. South Hamilton, Ontario L8N 2K7 

CANADA 

Business Phone: (905) 522-4651 
Business Fax: (905) 529-5856 
Home Phone: 

Home Fax: 

E-Mail: langleyparisian@sympatico.ca 
Web Site: 


Mr. Aldridge, Mahlon 

Director, Pollution Prevention Programs 

Ecology Action, Inc. 

P.O. Box 1188 Santa Cruz, CA 95061-1188 USA 

Business Phone: 408-426-5925 xl6 

Business Fax: 408/425-1404 

Home Phone: 408/457-9275 

Home Fax: 408/426-2533 

E-Mail: emahlon@ecoact.org 

Web Site: www.ecoact.org 


Dr. Allenby, Braden R. 

Vice President 

AT&T Environment, Health & Safety 
20 Independence Blvd. 

Rm# 4B42 Wanen, NJ 07059 
Business Phone: 908/580-5800 
Business Fax: 908/580-6633 
Home Phone: 

Home Fax: 

E-Mail: ballenby@att.com 
Web Site: 


Ms. Armbruster, Melinda 

Battelle 

505 King Ave Columbus, OH 43201 
Business Phone: 614/424-4911 
Business Fax: 614/424-4250 
Home Phone: 

Home Fax: 

E-Mail: armbruster@battelle.org 
Web Site: 


Mr. Barlow, Ed 
President 

Creating the Future, Inc. 

1783 Briarcliff 

Suite 100 St. Josephs, MI 49085 
Business Phone: 616/429-2601 
Business Fax: 616/429-2603 
Home Phone. 

Home Fax: 

E-Mail: barlow@QTM.NET 
Web Site: 


Ms. Barnett, Debbie 
Director-District Four 

International Fabricare Institute (IFI) 

The Washboard 

7031 E. 10th Street Indianapolis, IN 46219 
Business Phone: 317/353-1286 
Business Fax: 317/322-0132 
Home Phone: 

Home Fax: 

E-Mail: debnett@indy.net 
Web Site: 


Dr. Bates, Stephen 
Chemist 

Rynex Holdings, Ltd. 

7600 Jericho Turnpike Woodbury, NY 11797 USA 
Business Phone: 516/364-8993 ext. 18 
Business Fax: 516/364-0802 
Home Phone: 

Home Fax: 

E-Mail: rrynex@aol.com 
Web Site: 


Mr. Battiston, Jeffrey 

Battiston Cleaners 

565 New Park Ave. W. Hartford, CT 06110 
Business Phone: 860/232-6930 
Business Fax: 860/231-9245 
Home Phone: 

Home Fax: 

E-Mail: batcol@aol.com 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Beard, Ross 
CEO 

R. R. Street & Co., Inc. 

184 Shuman Blvd. Naperville, IL 60563-8464 USA 
Business Phone: 630-416-4244 ext200 
Business Fax: 630-416-4150 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Becker, Paul 

Rynex Holdings, Inc. 

222 Wellington Road Mineola, NY 11501 
Business Phone: 516/739-8843 
Business Fax: 

Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Beckman, John T. 

Chemical Product Manager 

Laidlaw, Inc. 

1212 East 5th Street 
P.O. Box 480 Metropolis, IL 62960 
Business Phone: 800/851-7731 ext.210 
Business Fax: 618/524-2776 
Home Phone: 

Home Fax: 

E-Mail: tbeck23013@aol.com 
Web Site: 


Mr. Bell, Buster 
Owner 

Bell Laundry and Cleaners 

448 Marion Ave. Spartanburg, SC 29306 USA 

Business Phone: 864-583-8668 

Business Fax: 864-583-0202 

Home Phone: 

Home Fax: 

E-Mail: no email 
Web Site: 


Mr. Belluscio, Jack 

Global Technologies 

222 North Sepulveda Blvd., Suite 2200 El Segundo, CA 
90245 USA 

Business Phone: (310) 414-9684 
Business Fax: (310)414-9682 
Home Phone: 

Home Fax: 

E-Mail: jbelluscio@gIobaltechno.com 
Web Site: 


Ms. Bering, Merry 

Michigan Institute of Laundering & Drycleaning, Inc. 
(MILD) 

PO Box 14044 Lansing, MI 48901 
Business Phone: 517-337-2909 
Business Fax: 517-337-2811 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Ms. Berlin-Blackman, Ann 

University of Massachusettes Lowell 
1 University Ave. Lowell, MA 01854 USA 
Business Phone: 978/934-3124 
Business Fax: 978/934-3050 
Home Phone: 

Home Fax: 

E-Mail: blackman@turi.org 
Web Site: 


Dr. Beming, Carol K. 

Research Fellow 

The Procter & Gamble Company 

6060 Center Hill Ave. Cincinnati, OH 45224 

Business Phone: 513/634-6180 

Business Fax: 513/634-6103 

Home Phone: 

Home Fax: 

E-Mail: beming.ck@pg.com 
Web Site: 






EPA Dfe GTCP 
1998 Conference Attendees 


Ms. Birnbaum, Nancy 
Environmental Protection Specialist 

US EPA Office of Reinvention 

401 M Street SW( 1802) Washington, DC 20460 

Business Phone: 202/260-2601 

Business Fax: 202/401-2474 

Home Phone: 

Home Fax: 

E-Mail: bimbaum.nancy@epa.gov 
Web Site: 


Mr. Bogert, John 

South Central Sales Manager 

Boewe Permac (BUFA) 

13628 Beta Road Dallas, TX 75244 
Business Phone: 972/3 17-9686 
Business Fax: 972/317-0843 
Home Phone: 

Home Fax: 

E-Mail: jcbogert@concentric.net 
Web Site: 


Mr. Bolon, Paul 
Director of Policy 

OSHA- US Labor Dept 

200 Constitution Ave. NW, Room N3627 Washington, 
20210 USA 

Business Phone: 202/693-1960 
Business Fax: 202/693-1641 
Home Phone: 

Home Fax: 

E-Mail: paul.bolon@osha-no.osha.gov 
Web Site. 


Ms. Boorstein, Ruth 

Prestige...Exceptional Fabricare 

9420 Georgia Ave. Silver Spring, MD 20910-1434 

Business Phone: 301/588-0333 

Business Fax: 301/588-7914 

Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Boyle, Joseph 
Environmental Specialist 

US EPA 

401 M. Street SW (7408) 

WSM E511C Washington, DC 20460 
Business Phone: 202/260-1802 
Business Fax: 202/260-2219 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Dr. Breen, Joseph 
Executive Director 

Green Chemistry Institute 

1650 Research Blvd Rockville, MD 20850 

Business Phone: (301) 294-2854 

Business Fax: (301) 294-2829 

Home Phone: (703)243-1248 

Home Fax: 

E-Mail: BREENJl@westat.com 
Web Site: 


Mr. Boorstein, Edward 
President 

Prestige...Exceptional Fabricare 

9420 Georgia Ave. Silver Spring, MD 20910- 

Business Phone: 301-588-0333 

Business Fax: 301/588-7914 

Home Phone: 301/493-5060 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Burt, Robert 
Acting Director 

OSHA / Office of Regulatory Analysis 
USA 200 Constitution Ave. 

N3627 Washington, DC 20210-0001 
Business Phone: 202/219-4690 ext. 139 
Business Fax: 202/219-4383 
Home Phone: 

Home Fax: 

E-Mail: robert.burt@osha-no.osha.gov 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Dr. Buxton, Bruce 

Battelle 

505 King Ave. Columbus, OH 43201 USA 
Business Phone: 614-424-4547 
Business Fax: 614-424-4250 
Home Phone: 

Home Fax: 

E-Mail: buxtonb@battelle.org 
Web Site: 


Mr. Carra, Joseph 
Deputy Director 

US EPA 

Office of Pollution Prevention and Toxic Substances 
401 M. Street SW (7401) Washington, DC 20460 
Business Phone: 202/260-1815 
Business Fax: 202/260-0575 
Home Phone: 

Home Fax: 

E-Mail: carra.joe@epamail.epa gov 
Web Site: 


Dr. Cassill, Nancy 

School of Human Ei'vironmental Sciences 

Umv of NC, Dept of Clothing and Textiles 

210 Stone Building Greensboro, NC 27412-5001 USA 

Business Phone: 336/334-5250 

Business Fax: 336/334-5614 

Home Phone: 336/282-0166 

Home Fax: 

E-Mail: cassillm@iris.uncg.edu 
Web Site: 


Mr. Chadbourne, Joe M. 

Project Coordinator 

Camp, Inc. 

Organochlorine project 

18554 Haskins Road Chiagrin Falls, OH 44023-1823 
USA 

Business Phone: 440/543-7303 
Business Fax: 440/543-7160 
Home Phone: 

Home Fax: 

E-Mail: mmjhchadboume@compuserve.com 
Web Site: 


Ms. Chadbourne, Mary 
Project Coordinator 

Camp, Inc. 

Organochlorine Project 

18554 Haskins Road Chiagrin Falls, OH 44023-1823 
Business Phone: 440/543-7303 
Business Fax: 440/543-7160 
Home Phone: 

Home Fax: 

E-Mail, mmjhchadboume@compuserve.com 
Web Site: 


Mr. Childers, Everett 
Consultant & Educator 

P.O. Box 1005 Vancouver, WA 98660 USA 
Business Phone: 360/750-5684 
Business Fax: 360/750-5684 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Cho, Abraham 
Environmental Protection Advisor 

Korean-American Cleaners Association of New Jersey 
Mountainside Cleaners 

512 Lincoln Hwy., 2nd Floor Iselin, NJ 08830 USA 
Business Phone: 732/283-5135 
Business Fax: 732/283-5137 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Ms. Cho, Jenni 
Program Manager 

Korean Youth and Community Center K.Y.C.C. 

680 South Wilton Place Los Angeles, CA 90005 USA 
Business Phone: (213) 365-7400 xl 18 
Business Fax: (213) 383-1280 
Home Phone: 

Home Fax: 

E-Mail: jcho@kycc.apnet.org 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Choi, Sam 

Vice President of Asian Affairs 

International Fabricare Institute 

12251 Tech Road Silver Spring, MD 20904 USA 

Business Phone: 301-622-1900 ext. 148 

Business Fax: 301-622-1568 

Flome Phone: 

Home Fax: 

E-Mail: asianaffairs@ifi.org 
Web Site: 


Mr. Chun, Moon Jong 
President 

Federation of Korean Drycleaners Associations 
Sanda II 

215 Elm Street New Canaan, CT 06840 
Business Phone: 203/966-2019 
Business Fax: (203) 966-3609 
Home Phone: 203/834-2785 
Home Fax: 

E-Mail: no email 
Web Site: 


Mr. Coffie, Dave 

Environmental Protection Specialist 

Defense Logistics Agency 

8725 John J. Kingman Road Ft. Belvoir, VA 22060-6221 
USA 

Business Phone: 703/767-2614 
Business Fax: 703/767-2628 
Home Phone: 

Home Fax: 

E-Mail: david_cofne@hq.dla.mil 
Web Site: 


Mr. Cotter, Dave 

Textile Care Allied Trades Association (TCATA) 

271 Rte 46 West, Suite D203 Fairfield, NJ 07004 USA 
Business Phone: 973/244-1790 
Business Fax: 973/244-4455 
Home Phone: 

Home Fax: 

E-Mail, tcata@ix.netcom.com 
Web Site: 


Dr. Daniels, John 
Executive Director 

AATCC 

I Davis Drive Research Triangle Park, NC 27709 
Business Phone: 919/549-8141 
Business Fax: 919/549-8933 
Home Phone. 

Home Fax: 

E-Mail: danielsj@aatcc.org 
Web Site: 


Mr. Darvin, Charles H. 

US EPA/ORD 

NRMRL-APPCD (MD-61) Research Triangle Park, NC 
27711 USA 

Business Phone: (919) 541-7633 
Business Fax: (919) 541-7891 
Home Phone: 

Home Fax: 

E-Mail: cdarvin@engineer.aeerl.epa.gov 
Web Site: 


Ms. Davis, Debra 
Cleaner By Nature 

3317 La Cienega Los Angeles, CA 90016 USA 
Business Phone: 310/315-1520 
Business Fax: 310/815-8405 call 1st 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Dr. Davis, Mike 

Westat, Inc. 

1600 Research Blvd. 

RA 1408 Rockville, MD 20850 USA 
Business Phone: 301/294-2833 
Business Fax: 301/294-2829 
Home Phone: 

Home Fax: 

E-Mail: davisml@westat.com 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Dawson, David 

Textile Care Allied Trades Association (TCATA) 
184 Shuman Blvd. 

Suite 150 Naperville, IL 60563 
Business Phone: 630/416-6716 
Business Fax: 630/416-4150 
Home Phone: 

Home Fax: 

E-Mail: dawson2436@aol.com 
Web Site: 


Ms. Della Torre, Karen 

Westat, Inc. 

1600 Research Blvd. 

RA 1438 Rockville, MD 20850 USA 
Business Phone: 301/294-2832 
Business Fax: 301/294-2829 
Home Phone: 

Home Fax: 

E-Mail: dellatkl@westat.com 
Web Site: 


Mr. DeRosa, Dave 

Greenpeace 

417 South Dearborn Street 
Suite 420 Chicago, IL 60605 USA 
Business Phone: 312/554-1028 
Business Fax: 312/554-1224 
Home Phone: 

Home Fax: 

E-Mail: david.derosa@dialb.greenpeace.org 
Web Site: 


Mr. Deutsch, Joel 
Executive Director 

Southeastern Fabricare Association (SEFA) 

500 Sugar Mill Rd, Suite 200-A Atlanta, GA 30350-2886 
USA 

Business Phone: 800-998-7332 
Business Fax: 770-998-1441 
Home Phone: 

Home Fax: 

E-Mail: SEFA.clnrs@worldnet.att.net 
Web Site: 


Mr. Dickinson, Elden 
Chief Drycleaning Program 

Michigan Dept, of Environmental Quality 

3423 North Martin Luther King Jr. Blvd. Lansing, MI 

48906 

Business Phone: 517/335-8251 
Business Fax: 517/335-9033 
Home Phone: 

Home Fax: 

E-Mail: dickinsone@state.mi.us 
Web Site: 


Ms. Eggert, Liz 
Research Associate 

The Procter & Gamble Company 

Ivorydale Technical Center 

5299 Spring Grove Ave. Cincinnati, OH 45217 

Business Phone: 513/627-5824 

Business Fax: 513/627-5690 

Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Ms. Engel, Eileen 

Deputy Exec. Director of Natl PETE 
PETE 

6601 Owen Drive 
Suite 235 Pleasenton, CA 94588 
Business Phone: 925/225-0069 
Business Fax: 925/225-0679 
Home Phone: 

Home Fax: 

E-Mail: edengel@worldnet.att.net 
Web Site: www.pete.org 


Dr. Engelbach, Peggy 
Assistant Professor 

Indiana State University 

Department of Family and Consumer Sciences Terre 
Haute, IN 47809 USA 
Business Phone: (812) 237-3305 
Business Fax: 

Home Phone: 

Home Fax: 

E-Mail: p-engelbach.indstate.edu 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Ms. Engle, Mary K. 

Assistant Director of the Enforcement Div. 

Mr. Fischer, Earl V. 

Editor 

Federal Trade Commission 

601 Pennsylvania Avenue, N.W., Room 4302(S) 
Washington, D C. 20580 

Business Phone: (202) 326-3161 

Business Fax: (202) 326-2558 or 3259 

Home Phone: 

Home Fax: 

E-Mail: mengle@ftc.gov 

Web Site: 

American Drycleaner 

Crain Associated Enterprises Inc. 

500 N Dearborn Chicago, IL 60610 USA 

Business Phone: 312/337-7700 

Business Fax: 312/337-8654 

Home Phone: 

Home Fax: 

E-Mail: TheJID@aol.com 

Web Site: 

Ms. Ewing, Sylvia 

Mr. Fisher, Bill 

Center for Neighborhood Technology 

International Fabricare Institute (IFI) 


2125 West North Avenue Chicago, IL 60647 USA 12251 Tech Road Silver Spring, MD 20904 


Business Phone: 773/278-4800 x 129 

Business Fax: 773/278-3840 

Home Phone: 

Home Fax: 

E-Mail: sylvia@cnt.org 

Web Site: 

Business Phone: (301) 622-1900 (xl 13) 

Business Fax: (301) 236-9320 

Home Phone: 

Home Fax: 

E-Mail: fisher@ifi.org 

Web Site: 

Ms. Fain, Sharon 

Director 

Mr. Frumin, Eric 

Cuyahoga Community College 

Unified Technologies Center 

Union of Needletrades, Indus and Textile Employees 
(UNITE) 

Department of Occupational Safety and Health, 


2415 Woodland Ave. Rm 240 Cleveland, OH 44115-3239 275 Seventh Ave., 6th Floor New York, NY 10001 USA 


USA 

Business Phone: 216/987-3086 

Business Fax: 216/987-3246 

Home Phone: 

Home Fax: 

E-Mail: sharon.fain@tri-c.cc.oh.us 

Web Site: 

Business Phone: (212) 691 -1691 

Business Fax: (212) 807-0874 

Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 

Dr. Fiksel, Joseph 

Ms. Giddings, Charlotte E. 

Attorney 

Battelle 

505 King Ave. Columbus, OH 43201-2693 USA 
Business Phone: 614-424-6424 ext5730 

Business Fax: 614-424-3404 

Home Phone: 

Home Fax: 

E-Mail: fikselj@battelle.org 

Web Site: 

Baise, Miller & Freer, P.C. 

815 Connecticut Ave., NW 

Suite 620 Washington, DC 20006 

Business Phone: 202/331-9100 

Business Fax: 202/331-9060 

Home Phone: 

Home Fax: 

E-Mail: cgiddings@aol.com 

Web Site: 


1 


EPA Dfe GTCP 
1998 Conference Attendees 


Dr. Goldman, Lynn 
Assistant Administrator 

US EPA 

Office of Prevention Pesticides and Toxic Substances 
401 M Street SW (7101) Washington, DC 20460 
Business Phone: 202/260-2902 
Business Fax: 202/260-1847 
Home Phone: 

Home Fax: 

E-Mail: goldman.lynn@epamail.epa.gov 
Web Site: 


Ms. Gomes, Filomena 
Development Chemist 

Unilever HPS-USA 
45 River Road Edgewater, NJ 07020 
Business Phone: 201/840-2578 
Business Fax: 201/840-8299 
Home Phone: 

Home Fax: 

E-Mail: filomena.gomes@unilever.com 
Web Site: 


Dr. Grady, Perry L. 

Assoc Dean, Professional Engineer 

North Carolina State University 
College of Textiles 

Box 8301, NCSU Raleigh, NC 27695-8301 USA 
Business Phone: 919-515-6651 
Business Fax: 919-515-3057 
Home Phone: 

Home Fax: 

E-Mail: perry_grady@ncsu.edu 
Web Site: 


Mr. Greco, Richard J 

National Sales Manager/Drycleaning 

Hoffman/New Yorker, Inc. 

25 Lackawanna Place Bloomfield, NJ 07003-2401 
Business Phone: 973/748-0500 ext.22 
Business Fax: 973/748-1341 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Dr. Gottlieb, Bob 

UCLA Wet Cleaning Project 
Occidental College 

1600 Campus Rd. Los Angeles, CA 90041-3314 USA 
Business Phone: 213/259-2712 
Business Fax: 213/259-2734 
Home Phone: 

Home Fax: 

E-Mail: gottlieb@oxy.edu 
Web Site: pperc@oxy.edu 


Mr. Gouveia, Patrick A. 

Navy Clothing and Textile Research Facility 
P.O. Box 59 Natick, MA 1760 USA 
Business Phone: (508) 233-4740 
Business Fax: (508) 233-4683 
Home Phone: 

Home Fax: 

E-Mail: pgouveia@natick-amed02.army.mil 
Web Site: 


Mr. Gregson, Martin F. 

Group Technical Director 

Johnson Group Management Services, Ltd. 
Mildmay Road, Bootle Liverpool, UK L20 5EW 
ENGLAND 

Business Phone: 0151 933-6161 
Business Fax: 0151 922-8089 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Han, Tae Hee 
President 

Korean-American Cleaners Association of New Jersey 
Mountainside Cleaners 

512 Lincoln Hwy., 2nd Floor Iselin, NJ 08830 USA 
Business Phone: 732/283-5135 
Business Fax: 732/283-5137 
Home Phone: 

Home Fax: 908/232-1261 
E-Mail: none 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Hanson, Bill 
Chief 

US EPA DfE Branch 

401 M. Street, SW (7406) Washington, DC 20460 
Business Phone: 202-260-0686 
Business Fax: 202-260-0981 
Home Phone: 

Home Fax: 

E-Mail: hanson.bill@epamail.epa.gov 
Web Site: 


Dr. Hasselbrack, Sally 
Technical Fellow 

Boeing Commercial Airplane Group 
USA Mail stop OR-TX 

P O. Box 3707 Seattle, WA 98124 USA 
Business Phone: 425/342-9947 
Business Fax: 425/266-9041 
Home Phone: 

Home Fax: 

E-Mail: sally.a.hasselbrack@boemg.com 
Web Site: 


Ms. Hargrove, Ann 

Ann Hargrove and Associates 

8132 Salisbury Avenue Lyons, IL 60534 USA 

Business Phone: (708) 447-0879 

Business Fax: 708/447-0879 

Home Phone: 

Home Fax: 

E-Mail, wetclean@aol.com 
Web Site: AHargro7630@aol.com 


Dr. Harlan, Jerry 

Head of Research Laboratory 

ADCO, Inc. 

900 West Main Street (or) 

P.O. Box 999 Sedalia, MD 65301 USA 
Business Phone: 800/821-7556 
Business Fax: 660/826-1361 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site. 


Mr. Hartley, James 
Vice President 

Phenix Supply Co. 

1920 Tampa East Blvd. Tampa, FL 33619 USA 
Business Phone: 813/623-3553 
Business Fax: 813/623-3558 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Dr. Helms, Tucker 
Executive Director 

Ecological & Toxicological Association (ETAD) 

1850 M Street NW #700 Washington, DC 20036 
Business Phone: 202/721-4154 
Business Fax: 202/296-8120 
Home Phone: 

Home Fax: 

E-Mail: helms@socma com 
Web Site: 


Mr. Hoenscheid, Joe 

Defense Logistics Agency 

8725 John J. Kingman Road Ft. Belvoir, VA 22060-6221 
Business Phone: 703/767-2643 
Business Fax: 703/767-2628 
Home Phone: 

Home Fax: 

E-Mail: joe_hoenscheid@hq.dla.mil 
Web Site: 


Dr. Hoffmann, Thomas L. 

Technology Development Manager 

Fraunhofer Technology Center 
601 West 20th Street Hialeah, FL 33010 
Business Phone: 305/863-9096 
Business Fax: 305/863-9097 
Home Phone: 

Home Fax: 

E-Mail: tlh@FTeCH.org 
Web Site: www FTeCH org 


EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Horning, Hal 
Editor 

National Clothesline 
801 Easton Road 

Suite 2 Willow Grove, PA 19090 
Business Phone: 215/830-8467 
Business Fax: 215/830-8490 
Home Phone: 

Home Fax: 

E-Mail: hhommg@pond.com 
Web Site: 


Ms. Hough, Suzanne 
Product Services Associate 

American Textile Manufacturers Institute 
1130 Connecticut Ave. Washington, DC 20036 
Business Phone: 202/862-0500 ext. 502 
Business Fax: 202/862-0570 
Home Phone: 

Home Fax: 

E-Mail: suzanne@atmi.org 
Web Site: 


Ms. Hunter, Janet 

Westat, Inc. 

1600 Research Blvd. 

RA 1433 Rockville, MD 20850 USA 
Business Phone: 301/315-5996 
Business Fax: 301/294-2829 
Home Phone: 

Home Fax: 

E-Mail: hunterjl@westat.com 
Web Site: 


Ms. Johnson, V F 
Consumer Specialist 

Fairfax Dept, of Consumer Affairs 
12000 Government Center Parkway 
Suite 433 Fairfax, VA 22035 
Business Phone: 703/324-5959 
Business Fax: 703/222-5921 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Mr. Jones, Michael 

President Nat’l Coalition of Petroleum Drycleaners 

Highland Cleaners 

2455 Bardston Road Louisville, KY 40205 
Business Phone: 502/454-4641 
Business Fax: 502/454-4646 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Mr. Jones, Robert 
Biologist 

US EPA 

401 M Street SW (7405) Washington, DC 20460 
Business Phone: 202/260-8150 
Business Fax: 202/260-1096 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Ms. Keesee, Susan 
Editorial Director 

AATCC 

I Davis Drive Research Triangle Park, NC 27709 
Business Phone: 919/549-8141 
Business Fax: 919/549-8933 
Home Phone: 

Home Fax: 

E-Mail: keesees@aatcc.org 
Web Site: 


Ms. Keyes, Norma M. 

Director, Fiber Quality Research 

Cotton Incorporated 

4505 Creedmoore Road Raleigh, NC 27612 
Business Phone: 919-510-6165 
Business Fax: 919-881-9874 
Home Phone: 

Home Fax: 

E-Mail: nkeyes@cottoninc.com 
Web Site: 




EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Kim, Chi Soo 

President 

Mr. Kurz, Josef 

Business Mgr., Textile Care Research Division 

Korean Drycleaners Association of Atlanta 

Lux Cleaners 

5200 Jimmy Carter Blvd. Norcross, GA 30093 

Business Phone: 770/662-0063 

Business Fax: 

Home Phone: 770/729-9116 

Home Fax: 

E-Mail: 

Web Site: 

Hohenstein Institutes 

D-74357 Boenmgheim Schloss Hohenstein, GERMANY 
Business Phone: +49 07143-271-718 

Business Fax: 4971432718746 

Home Phone: 

Home Fax: 

E-Mail: j.kurz@hohenstein.de 

Web Site: 

Mr. Kim, Hank Gil 

Dr. Lakritz, Julian 

Director of Technology 

Federation of Korean DryCleaners Association (FKDA) 
25606 Alicia Parkway Laguna Hills, CA 92653 

Business Phone: (714) 770-8251 

Business Fax: (714) 770-1102 

Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 

Global Technologies 

222 N Sepulveda Blvd. El Segundo, CA 90245 

Business Phone: 310/414-9680 

Business Fax: 310/414-9682 

Home Phone: 

Home Fax: 

E-Mail: jlakritz@globaltechno.com 

Web Site: 

Mr. Kim, Kap Nyun 

President 

Ms. Lapinski, Michelle 

Environmental Analyst 

Korean Drycleaners Association of Greater Washington 
6647 B Old Dominion Drive McLean, VA 22101 
Business Phone: 703/847-9040 

Business Fax: 703/847-9040 

Home Phone: 

Home Fax: 

E-Mail: none 

Web Site: 

Gap, Inc. 

345 Spear Street 

2nd Floor San Francisco, CA 94105-1672 

Business Phone: 415/427-3448 

Business Fax: 415/427-5242 

Home Phone: 

Home Fax: 

E-Mail: michelle_lapmski@gap.com 

Web Site: 

Mr. Kinsman, Richard 

Director 

Mr. Latham, Steve 

Global Technologies 

222 No Sepulveda Blvd., Suite 2200 El Segundo, CA 
90245 USA 

Business Phone: 310-414-9680 

Business Fax: 310-414-9682 

Home Phone: 

Home Fax: 

E-Mail, rkinsman@globaltechno.com 

Web Site: 

Westat, Inc. 

1600 Research Blvd. 

RA 1498 Rockville, MD 20850 USA 

Business Phone: 301/294-2836 

Business Fax: 301/294-2829 

Home Phone: 

Home Fax: 

E-Mail: Iathamsl@westst.com 

Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Leiken, Sid 
Owner 

Prestige Cleaners 

1460 Mohawk Blvd. Springfield, OR 97477 
Business Phone: 541/746-9013 
Business Fax: 541/746-2235 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Ms. Lovelady, Andrea 
Marketing Coordinator 

R.R. Street & Co., Inc. 

184 Shuman Blvd. Naperville, IL 60563 
Business Phone: 630/416-4244 
Business Fax: 630/416-4150 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Luiken, Richard 
Manufacture Representative 

Richards Associates 

403 Lakeview Avenue Milford, DE 19963 USA 

Business Phone: 800/270-1618 

Business Fax: 302/422-5124 

Home Phone: 302/422-3600 

Home Fax: 

E-Mail: rcluik@delnet.com 
Web Site: 


Dr. Machacek, Margit 

JC Penney Company, Inc. 

Quality Assurance Center, 

1505 Wallace Drive, Suite 102 Carrollton, TX 75006 
USA 

Business Phone: (972) 431 -9816 
Business Fax: (972) 245-1147 
Home Phone: 

Home Fax: 

E-Mail: mmachace@jcpenney.com 
Web Site: 


Ms. Macklin, Chris 
Research Associate 

The Procter & Gamble Company 

Winton hill Technical Center 

6060 Center Hill Ave. Cincinnati, OH 45224 

Business Phone: (513) 634-7285 

Business Fax: (513) 634-1811 

Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Ms. Maillefer, Christiane 

North Carolina State University 

Dept, of Chemical Engineering 

Box 7905, Room 104 Raleigh, NC 27695 

Business Phone: 919/515-7054 

Business Fax: 919/515-3465 

Home Phone: 

Home Fax: 

E-Mail: cmaill@unity.ncsu.edu 
Web Site: 


Mr. Mains, Harold 
Vice President Research 

Fabritec International 

200 Industrial Road Cold Spring, KY 41076 
Business Phone: 606/781-8200 
Business Fax: 606/781-8280 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Markey, Raymond 

US Army Soldiers Systems Command 
Kansas Street Natick, MA 01760-5019 USA 
Business Phone: 508/233-5433 
Business Fax: 508/233-4097 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Ms. Martin, Heather 

Mr. Meijer, Jon 

MCSR 

1150 17th Street NW 

Suite 604 Washington, DC 20036 

Business Phone: 202/887-9201 

Business Fax: 202/887-9233 

Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 

IFI 

12251 Tech Road Silver Spring, MD 20904 USA 
Business Phone: 301/622-1900 x 145 

Business Fax: 301/236-9320 

Home Phone: 

Home Fax: 

E-Mail: meijer@ifl.org 

Web Site: 

Mr. Maves, Tom 

Environmental Specialist 

Mr. Miller, Marshall 

Attorney 

OHIO EPA Office of Polution Prevention 

P.O. Box 1049 Columbus, OH 43216-1049 
Business Phone: 614/728-1261 

Business Fax: 614/728-1245 

Home Phone: 

Home Fax: 

E-Mail: tom.maves@epa.state.oh.us 

Web Site: 

Baise & Miller Law Firm 

815 Connecticut Ave. 

Suite 620 Washington, DC 20006 USA 

Business Phone: 202/331-9100 

Business Fax: 202/331-9060 

Home Phone: 

Home Fax: 

E-Mail: baisemill@aol.com 

Web Site: 

Mr. Mayberry, James 

Administrative Coordinator 

Dr. Mock, Gary N. 

Professor 

R.R. Street / FLARE 

184 Shuman Blvd. Naperville, IL 60563 

Business Phone: 630/416-6221 

Business Fax: 773/267-3032 

Home Phone: 

Home Fax: 

E-Mail: mfo_flare@aol.com 

Web Site: 

North Carolina State University 

Box 8301 Raleigh, NC 27695-8301 

Business Phone: 919-515-6457 

Business Fax: 919-515-6532 

Home Phone: 

Home Fax: 

E-Mail, gmock@tx.ncsu.edu 

Web Site: 

Dr. McClain, Jim 

Vice President, Technical Development 

Ms. Morgan, Jennifer 

MiCell Technologies, Inc. 

7516 Precision Drive Raleigh, NC 27613 

Business Phone: 919/313-2102 x 111 

Business Fax: 919/313-2103 

Home Phone: 

Home Fax: 

E-Mail: jmcclain@micell.com 

Web Site: 

Wool Bureau, Inc. 

330 Madison Ave. New York, NY 10017-5001 
Business Phone: 212/499-4254 

Business Fax: 212/557-5985 

Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Ms. Mueser, Karen 

Product Engineer for Textile Home Fashion 

Sears Roebuck & Co. 

3333 Beverly Road 

FC 575B HofTman Estates, IL 60169 USA 
Business Phone: 847/286-5975 
Business Fax: 847/286-5991 
Home Phone: 

Home Fax: 

E-Mail: ussmgg2e@ibmmail 
Web Site: 


Ms. Neri, Carol J. 

Supervisory Chemist/Color Science 

Defense Logistics Agency 

DLA Product Test Center/Def. Person. Supp. Ctr. (FQL) 
2800 S. 20th Street Philadelphia, PA 19145-5001 
Business Phone: 215/737-3265 
Business Fax: 

Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Nilsen, Joe 

Defense Personnel Support Center 

2800 South 20th Street Philadelphia, PA 19145-5099 

USA 

Business Phone: 215-737-2000 ext 3016 
Business Fax: 215/773-3172 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Norford, David 

Mid Atlantic Cleaners and Launderers Association 
MACLA 

5492 Riverview Drive King George, VA 22485 USA 
Business Phone: 540/775-2525 
Business Fax: 540/775-7441 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Mr. Oehlke, Norma 
Consultant 

7506 Greenwood Drive Highland, MD 20777 
Business Phone: 301/854-3977 
Business Fax: none 
Home Phone: 

Home Fax: 

E-Mail: adoehlke@juno.com 
Web Site: 


Mr. Oh, Max 
Advisor 

Korean Drycleaners Association of Greater Washington 

Town & Country Cleaners 

4715 Commerce Lane Bethesda, MD 20814 USA 

Business Phone: 301/654-1500 

Business Fax: 301/654-1503 

Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Mr. Ouimet, Albert B. 
Technical Director 


Mr. Nolan, Mike 
Textile Technologist 

US Army Soldiers 

Kansas Street Natick, MA 01760-5019 USA 
Business Phone: 508/233-5468 
Business Fax: 508/233-5496 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Wamaco 

Wamaco Technical Center, 

Airport Industrial Park Westerly, RI 2891 
Business Phone: (401) 596-2836 
Business Fax: (401) 596-2318 
Home Phone: 

Home Fax: 

E-Mail: aouimet@wamaco.com 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Dr. Overcash, Michael 

North Carolina State University 

Dept, of Chemical Engineering 

Box 7905, Room 113 Raleigh, NC 27695-7905 USA 

Business Phone: 919-515-2325 

Business Fax: 919-515-3465 

Home Phone: 

Home Fax: 

E-Mail: overcash@eos.ncsu.edu 
Web Site: 


Mr. Patrizi, Kurt 

Westat, Inc. 

1600 Research Blvd. 

RA 1492 Rockville, MD 20850 USA 
Business Phone: 301/294-2870 
Business Fax: 301/294-2829 
Home Phone: 

Home Fax: 

E-Mail: patnzkl@westat.com 
Web Site: 


Mr. Pentecost, John 
Esquire 

Linowes and Blocher 
1010 Wayne Ave. 

10th Floor Silver Spring, MD 20910 
Business Phone 301/650-7006 
Business Fax: 301/495-9044 
Home Phone: 

Home Fax: 

E-Mail: jtp@lmowes-law.com 
Web Site: 


Mr. Pravs, Andrew 

Technical Director, Corporate Textiles 

Liz Claiborne, Inc. 

One Claiborne Ave. North Bergen, NJ 07047 
Business Phone: 201/295-6625 
Business Fax: 201/295-6260 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Priestland, Carl H. 

American Apparel Manufacturers Association (AAMA) 
2500 Wilson Boulevard, Suite 301 Arlington, VA 22201 
USA 

Business Phone: (703) 524-1864 
Business Fax: (703) 522-6741 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Dr. Rabinovich, Beth 

W'estat, Inc. 

1600 Research Blvd. 

RA 1324 Rockville, MD 20850 USA 
Business Phone: 301/315-5965 
Business Fax: 301/294-2829 
Home Phone: 

Home Fax: 

E-Mail: rabinobl@westat.com 
Web Site: 


Mr. Racette, Tim 
Vice President 

R. R. Street & Co., Inc. 

184 Shuman Blvd. Naperville, IL 60563-8464 
Business Phone: 630/416-4244 x225 
Business Fax: 630/416-4150 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Reehorst, Bob 
Owner 

Reehorst Cleaners 

27303 Center Ridge Westlake, OH 44145 
Business Phone: 216/871-6444 
Business Fax: 216/871-5129 
Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Ms. Regazzi, Marilyn 

Supervisor Fabric Quality Assurance 

Patagonia 

259 West Santa Clara St. Ventura, CA 93001 
Business Phone: 805/667-4775 
Business Fax: 805/653-6355 
Home Phone: 

Home Fax: 

E-Mail: marilyn_regazzi@patagonia.com 
Web Site: 


Dr. Riggs, Charles 

Director of Texas Res. Ctr. For Laundry & Dryclean 

Texas Woman’s University 

P.O. Box 425529 Denton, TX 76204 USA 

Business Phone: (940) 898-2670 

Business Fax: (940) 898-2711 

Home Phone: 940/387-5725 

Home Fax: 

E-Mail: cnggs@twu.edu 
Web Site: 


Ms. Rising, Jane 
Instructor 

IFI 

12251 Tech Road Silver Spring, MD 20904 USA 
Business Phone: 301/622-1900 x 123 
Business Fax: 301/236-9320 
Home Phone: 

Home Fax: 

E-Mail: education@ifi.org 
Web Site: 


Dr. Risotto, Steve 
Executive Director 

Halogenated Solvents Industry Alliance 

2001 L St NW, Suite 506A Washington, DC 20036 

Business Phone: 202-775-0232 

Business Fax: 202/833-0381 

Home Phone: 

Home Fax: 

E-Mail: srisotto@hsia.org 
Web Site: 


Ms. Ruskin, Maureen 

OSHA/ORA 

200 Constitution Ave. NW 
Room N3627 Washington, DC 20210 
Business Phone: 202/693-1955 
Business Fax: 202/693-1641 
Home Phone: 

Home Fax: 

E-Mail: maureen.ruskin@osha-no.osha.gov 
Web Site: 


Dr. Sanders, William H. 

US EPA/OPPT 

401 M Street, S.W. (7401) 

Room E-539B Washington, D C. 20460 
Business Phone: (202) 260-3810 
Business Fax: (202) 260-0575 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Ms. Scalco, Mary 

International Fabricare Institute (IFI) 

12251 Tech Road Silver Spring, MD 20904 USA 
Business Phone: (301) 622-1900 X131 
Business Fax: (301) 236-9320 
Home Phone: 

Home Fax: 

E-Mail: scalco@ifi.org 
Web Site: 


Dr. Schreiber, Judy 
Research Scientist III 

New York State Department of Health 

Bureau of Toxic Substance Assessments 

2 University Place, Room 240 Albany, NY 12203 USA 

Business Phone: 518/458-6405 

Business Fax: 518/458-6372 

Home Phone: 

Home Fax: 

E-Mail: jss05@health.state.ny.us 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Dr. Schreiner, James L. 

Staff Mrkt. Dev. Rep. Intermediates Am. 

Exxon Chemical Company 

13501 Katy Freeway Houston, TX 77079-1398 USA 
Business Phone: 281-870-6237 
Business Fax: 281-588-2558 
Home Phone: 

Home Fax: 

E-Mail: no email 
Web Site: 


Ms. Schwass, Carolyn 
Owner 

Blue Ribbon Fabricare Center 
165 County Road 135 Jemison, AL 35085 
Business Phone: 205/688-2414 
Business Fax: 205/688-2414 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Segrave-Daly, Richard 
Manager, Business Assistance Center 

U S. EPA Region 3 

841 Chestnut Building Philadelphia, PA 19107-4431 
Business Phone: 800/228-8711 
Business Fax: 215/566-5103 
Home Phone. 

Home Fax: 

E-Mail: daly.richard@epamail.epa.gov 
Web Site: 


Dr. Shahady, Thomas 

Catawba Valley Community College (CVCC) 
CVCC 

2550 Hwy. 70 SE Hickory, NC 28602 USA 
Business Phone: 704-327-7000 ext. 101 
Business Fax: 704-327-7276 
Home Phone: 

Home Fax: 

E-Mail: cvcc.cc.nc.us 
Web Site. 


Mr. Silverman, Dan 
President 

AHA Unlimited 

34891 Boheny Place Capistrano Beach, CA 926243 
Business Phone. 714/487-2042 
Business Fax: 714/487-1451 
Home Phone: 

Home Fax: 

E-Mail: 2aha@home.com 
Web Site: 


Dr. Sinsheimer, Peter 

PPERC 

Occidental College 

1600 Campus Road Los Angeles, CA 90041-3314 USA 
Business Phone: 323/259-1420 
Business Fax: 323/259-2734 
Home Phone: 

Home Fax: 

E-Mail: psinshei@ucla.edu 
Web Site: 


Mr. Seitz, William Ms. Snyder, Corey 

Executive Director Senior Engineer 


Neighborhood Cleaners Association-International (NCAI) 

252 West 29th Street New York, NY 10001-5201 USA 

Business Phone: (212) 967-3002 x23I 

Business Fax: (212) 967-2240 

Home Phone- 

Home Fax: 

E-Mail: ncai@sprynet.com attn: Bill Seitz 
Web Site: 


The Procter & Gamble Company 

6060 Center Hill Road Cincinnati, OH 45224 

Business Phone: 513/634-6241 

Business Fax: 513/634-1811 

Home Phone: 

Home Fax: 

E-Mail: snyder.cs@pg.com 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Snyder, Russ 
Executive for NCPD 

National Coalition of Petroleum Drycleaners 

4041 Powder Mill Road 

Suite 404 Calverton, MD 20705 

Business Phone: 301/348-2014 

Business Fax. 301/348-2020 

Home Phone: 

Home Fax: 

E-Mail: smslwest@aol.com 

Web Site, russsnyder@asphaltroofmg.org 


Mr. Speicher, Dale 
Sales Consultant 

Laidlaw Corporation 

6625 N. Scottsdale Road Scottsdale, AZ 85250 
Business Phone: 602/951-0003 
Business Fax: 602/991-1563 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 


Mr. Star, Anthony 

Center for Neighborhood Technology (CNT) 

2125 West North Avenue Chicago, IL 60647 USA 
Business Phone: (773) 278-4800 XI17 
Business Fax: (773) 278-3840 
Home Phone: 

Home Fax: 

E-Mail: astar@cnt.org 
Web Site: 


Ms. Stephens, Jackie 
1FI 

12251 Tech Road Silver Spring, MD 20904 USA 
Business Phone: 301/622-1900 xl26 
Business Fax: 301/236-9320 
Home Phone: 

Home Fax: 

E-Mail: stephens@ifi.org 
Web Site: 


Ms. Stroup, Cindy 

Manager, Garment & Textile Care Program 

US EPA OPPT/EETD 
401 M Street, SW(7406) 

Room 341 Washington, DC 20460 USA 
Business Phone: (202) 260-3889 
Business Fax: 202/260-0981 
Home Phone: 703/525-8680 
Home Fax: 

E-Mail: stroup.cmdy@epamail.epa.gov 
Web Site: 


Mr. Talbot, Gene 
Non-adjunct Professor 

Fashion Institute of Technology 
15 Enness Ave. Bethpage, NY 11714 
Business Phone: 212/217-8996 
Business Fax: 212/217-7593 
Home Phone: 516/681-9163 
Home Fax: 5 16/681-9163 
E-Mail: none 
Web Site: 


Dr. Taylor, Craig M.V. 

Principal Investigator 

Los Alamos National L aboratory 
CST-I2 

Supercritical Fluids Facility, J964 Los Alamos, NM 87545 
USA 

Business Phone: 505-665-3545 
Business Fax: 505-667-6561 
Home Phone: 

Home Fax: 

E-Mail: eggus_taylor@lanl.gov 
Web Site: 


Mr. Trevigne, Leroy J. 

Pellerin Milnor Corporation 
700 Jackson St. Kenner, LA 70062 USA 
Business Phone: 504-467-9591 ext 435 
Business Fax: 504/468-9307 
Home Phone: 

Home Fax: 

E-Mail: 

Web Site: 




EPA Dfe GTCP 
1998 Conference Attendees 


Ms. Underly, Kristina K. 

Senior Engineer 

Whirlpool Corporation 

The Elisha Gray II Research/Engineering Ctr. 

750 Monte Road, MD 5155 Benton Harbor, MI 49022 
Business Phone: 616/923-3916 
Business Fax: 616/923-3927 
Home Phone: 

Home Fax: 

E-Mail: kristina_k_underly@email.whirlpool.com 
Web Site: 


Ms. Villa, Kay M. 

American Textile Manufacturers Institute 

1130 Connecticut Avenue, N.W., Suite 1200 Washington, 

DC. 20036 USA 

Business Phone: (202) 862-0518 

Business Fax: (202) 862-0570 

Home Phone: 

Home Fax: 

E-Mail: kvilla@atmi.org 
Web Site: 


Mr. Vandermolen, Vic 

CanadianFabricare Association 

P.O. Box 24026 Kitchener, Ontario N2M 5P1 Canada 

Business Phone: 519-576-4500 

Business Fax: 519-576-8869 

Home Phone: 

Home Fax: 

E-Mail: maden@golden.net 
Web Site: 


Ms. Vecellio, Connie 

Federal Trade Commission 

601 Pennsylvania Avenue, N.W., Room 4302(S) 

4th floor Washington, D.C 20580 USA 

Business Phone: (202) 326-2966 

Business Fax: (202) 326-2558 

Home Phone: 

Home Fax: 

E-Mail: cvecellio@ftc.gov 
Web Site: 


Mr. Vigon, Bruce 

Battelle 

505 King Ave. Columbus, OH 43201-2693 USA 
Business Phone: 614-424-4463 
Business Fax: 614-424-3404 
Home Phone: 

Home Fax: 

E-Mail: vigonb@battelle.org 
Web Site: 


Dr. Wakelyn, Phillip 

National Cotton Council 

1521 New Hampshire Ave Washington, DC 20036 USA 
Business Phone: 202/745-7805 
Business Fax: 202/483-4040 
Home Phone: 

Home Fax: 

E-Mail: pwakelyn@cotton.org 
Web Site: 


Ms. Warren, Barbara 

Consumer's Union 

101 Truman Avenue Yonkers, NY 10703-1057 USA 

Business Phone: 914/378-2456 

Business Fax: 914/378-2928 

Home Phone: 718/984-6446 

Home Fax: 718/984-0500 

E-Mail: cpi@igc.apc.org 

Web Site: 


Dr. Weber, Mary Ellen 

US EPA-EETD 

401 M Street, SW (7406) 

Rm# E315B Washington, DC 20460 USA 
Business Phone: 202-260-0667 
Business Fax: 

Home Phone: 

Home Fax: 

E-Mail: weber.maryellen@epamail.epa.gov 
Web Site: 


EPA Dfe GTCP 
1998 Conference Attendees 


Mr. Weinberg, Jack 
Senior Toxics Campaigner 

Greenpeace 

417 South Dearborn Street 
Suite 420 Chicago, IL 60605 
Business Phone: (312) 563-6066 
Business Fax: (312) 563-6099 
Home Phone: 

Home Fax: 

E-Mail: jack.wemberg@dialb.greenpeace.org 
Web Site: 


Ms. Weiner, Debra 

Business for Social Responsibility 
1612 K Street NW 
Suite 706 Washington, DC 20006 
Business Phone: 202/463-0826 
Business Fax: 202/463-3954 
Home Phone: 

Home Fax: 

E-Mail: dweiner@bsr.org 
Web Site: 


Dr. W entz, Manfred 

North Carolina State University 
College of Textiles 

2401 Research Drive Raleigh, NC 27695 USA 
Business Phone: 919/513-3020 
Business Fax: 919/515-6532 
Home Phone: 

Home Fax: 

E-Mail: mcwentz97@msn.com 
Web Site: 


Mr. Won, Chris 

Chairman of the Environmental Prot. Comm. 

Federation of Korean Drycleaners Association 

Eastern Machinery Corp 

3395 Fox Street NW Duluth, GA 30136 

Business Phone: 770/497-0473 

Business Fax: 770/497-0473 

Home Phone: 

Home Fax: 

E-Mail: none 
Web Site: 


Mr. Yogis, George J. 

Global Manager Cleaning & Personal Care 

ARCO Chemical Company 

3801 West Chester Pike Newtown Square, PA 19073-2387 
Business Phone: 610/359-3299 
Business Fax: 610/359-5530 
Home Phone: 

Home Fax. 

E-Mail: cnsgjy@arcochem.com 
Web Site: 


Mr. Wintz, Dave 
Environmental Mgr 

Indiana Dept of Environmental Mgt 
IDEM-OPPTA 

100 North Senate Ave, P.O. Box 6015 Indianapolis, IN 
46204-2211 

Business Phone: 317/233-1194 
Business Fax: 317/233-5627 
Home Phone: 

Home Fax: 

E-Mail: dwintz@dem.state.in.us 
Web Site: 














’ 



















































REPORT DOCUMENTATION 
PAGE 

1. REPORT NO. 

EPA 744-R-98-006 

2. 

3. Recipient's Accession 

No. 

Not Applicable 

4. Title and Subtitle 

Garment and Textile Care Program -- An Eye to the Future: 1998 Conference 
Proceedings 

5. Report Date June 

1998 

6. 

7. Author(s) As this document is a conference proceedings, it consists of the 
narratives of presentations (and slides/viewgraphs/handouts) provided by those 
individuals who gave presentations at the EPA’s 1998 Garment and Textile Care 
Program National Conference. There were a total of 27 speakers who collectively 
represented public interest groups, state government, academia, fabricare 
industry, textile and garment industry, garment retail industry, equipment 
manufacturers, and EPA and other federal governmental agencies. 

8. Performing Organization 
Rept. No. EPA 744-R-98- 
006 

9. Performing Organization Name and Address 

U.S. Environmental Protection Agency 

Office of Pollution Prevention and Toxics (7406) 

401 M Street, S.W. 

Washington, D C. 20460 

10. Project/Task/Work Unit 

No. 

Task No. 2-01-01 

11. Contract(C) or Grant(G) 
No. 

(C) 68-W7-0025 
(G) 

12. Sponsoring Organization Name and Address 

U.S. Environmental Protection Agency 

Office of Pollution Prevention and Toxics/EETD (7406) 

401 M Street, S.W. 

Washington, D.C. 20460 

13. Type of Report & Period 
Covered, Final Report 

14. 

15. Supplementary Notes 

Management and overall technical direction were provided by Cindy Stroup, USEPA Design for the Environment 
Garment and Textile Care Program Manager. Editing and document preparation support was conducted by 

Westat under the direction of Kurt Patrizi. 

16. Abstract (Limit 200 words) The Garment and Textile Care Program -- An Eye to the Future: 1998 

Conference Proceedings was developed to document the presentations provided by the 27 conference speakers. 
The purpose of the conference was to explore how decisions made by the fabricare industry, garment retailing 
industry, textile industry, fibers industry, equipment and solvent manufacturing industry affect the incorporation of 
environmentally-preferable methods into professional clothes cleaning operations. The conference was the first 
step in the efforts of the EPA Garment and Textile Care Progam to incorporate a life cycle approach into 
decisions made throughout the fiber/textile/garment/retail/fabricare business pipeline. 

17. Document Analysis 

a. Descriptors: Drycleaning, wetcleaning, clothes cleaning, perchloroethylene, PCE, perc, chlorinated 
solvents, hydrocarbon solvents, textile production pipeline, life cycle, Design for the Environment, DfE, Garment 
and Textile Care Program, GTCP, value chain, garment care, petroleum solvents, alternative solvents, alternative 
technologies, fabricare processes, fabricare technologies, dry cleaning, wet cleaning, liquid carbon dioxide, 

Stoddard solvent, MiCELL, Rynex, Biotex, Global, Kirk’s. 

b. Identifiers/Open-Ended Terms: textiles, garments, solvents, fabricare, pollution prevention, carcinogen, 
green chemistry, industrial ecology. 

c. COSATI Field/Group: Not Applicable. 

18. Availability Statement 
Unlimited Availability 

19. Security Class (This Report): 

Unclassified 

21. No. of Pages 360 

20. Security Class (This Page) 

Unclassified 

22 Price 


(See ANSI-239.18) OPTIONAL FORM 272 (4-77) 


(Formerly NTIS-35) 

•u.s. Government Printing office: 1999 — 450-616/10174 Department of Commerce 
















































































































































LIBRARY OF CONGRESS 



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